Update on UCPD Compliance 1st Quarter · 2020-06-18 · Update on UCPD Compliance 1st Quarter: Jan...

Update onUCPD Compliance

1st Quarter: Jan 1 – Mar 31, 2018

Report Issued May 10, 2018

Presented to The Audit and Risk Management Committee

Overall Assessment Status• Initial Assessment of 208 of the 276 (75%) Exiger Recommendations• Substantial Compliance: 188 of 276 (68%) ERs• No Further Evaluation: 112 of 276 (41%) ERs• Not yet evaluated: 57 ERs• Partial Compliance: 15 ERs• Determination Withheld: 4 ERs• Non-Compliant: 1 (No annual refresher “Implicit Bias” training ER 2.2.B)

• Total Assessments: 280 ERs (71 were assessed more than once)

• Under Assessment: 32 ERs, to include 12 initial assessments, arecurrently being evaluated in Q6

Confidential 1

2017 2018 2019

127 ERs Assessed in 1st Bi-annual Period

109 ERs Assessed in 2nd Bi-annual Period

44 ERs Assessed in Q5

(year-to-date)

Q1: 54 Q3: 67 Q5: 44Q2: 73 Q4: 42

Overview of Initial Assessment: All 276 ERs

2

21

10

1719

27

33

1215

13 14 14 13

20 1 2

0

42 1 0 0 0 0

2 14

1

8

15

2

9

0 0

4

10

0

5

10

15

20

25

30

35

Initially Assessed Under Initial Assessment Not Yet Evaluated

Current Compliance AchievementsSubstantial Compliance with 188 of 208 (90%) ERs assessed:

• 86 in 1st bi-annual period• 97 in 2nd bi-annual period• 28 ERs in Q5 of 44 assessed

ERs can be assessed and achieve compliance more than once

_______________________________________________________Non-Compliant (NC) with 1 ER: assessed in Q5

NC = Did not meet requirements of ER

________________________________________________________Partial Compliance (PC) with 15 ERs: 11 assessed in Q5, 4 remain from prior assessments

PC = Significant progress made towards substantial compliance

________________________________________________________

Determination Withheld (DW) for 4 ERs: all assessed in Q5DW = Not able to complete compliance determination at this time

Confidential 3

Overview of Compliance: All 276 ERs by Section

4

0.0% 20.0% 40.0% 60.0% 80.0% 100.0%

Data Systems (23)

Technology (18)

Equipment (14)

Mental Health (13)

Comm Engage / POP (25)

Accountability (16)

Training (52)

Hiring and Promotions (35)

Policy and Procedures (22)

Use of Force (22)

Ped and Traffic Stops (11)

Fundamental Findings (25)

Overall (276)

Substantial Compliance: No Further Eval Substantial Compliance: RecurringPartial Compliance Determination WithheldNon Compliant Not Yet Evaluated

Overview of Compliance – Q5: 44 Total ERs Assessed

5

3 3

1

7

1

3

1 1

3

5

1

2

3

2

1 1 11 1 1 11

0

1

2

3

4

5

6

7

8

Compliance Status

Compliant Partial Compliance Determination Withheld Non Compliant

Q5 - Significant Topics • Collaborative Development to Several Key Policies:

− “Employee Conduct and Discipline”: including the Disciplinary Matrix; wasfinalized and disseminated in Q5

− “Arrests, Processing, Transportation of Detainees”: to be finalized, testedon, and disseminated in Q6

− In-Car Video Recording System: to be finalized and disseminated in Q6

− Internal Inspections Protocol and Annual Inspection Plan: to be finalizedand disseminated in Q6

• Training: continues to have documentation related problems identifiedduring implementation testing, to be resolved via collaborative targetedmeeting mid-May

• Hiring:− Three sworn officers hired since Jan 2017

− Two supervisor promotions (1 sergeant, 1 lieutenant)

− Filled positions for internal inspections lieutenant and crime analyst

Confidential 6

Change to Use of Force Policy

• Monitor’s review of Contact Cards resulted inidentification of UOF policy clarification regardingreporting un-holstering

• Update/clarification to policy:− Un-holstering weapon (firearm or Taser) no required reporting.

Once Taser/Axon equipment installed, these incidents will becaptured on BWC via activation of un-holstering (approx. 3-6months)

− Point weapon at person/”acquire a target” “laser lightcompliance” is a reportable incident on respective form andAdministrative Review (AR) conducted

− Actual use (firing) of weapon remains the same, results in UOFinvestigation

Confidential 7

Complaints and Uses of ForceCitizen Complaint/Internal Investigation

• Three Complaint Investigations were initiated in Q5• Two were Citizen’s Complaints and one was generated internally• None have been closed yet, but none are overdue (extended per policy)

• Involved UCPD employees: 2 sworn members, 1 Security Officer• Total of 50 Complaint/Internal Investigations since Jan 1, 2017

Use of Force (UOF)• One UOF incident in Q5 (bodily force/takedown and pointed Taser/CEW)

• Quality and timely investigation to include BWC review• Total of two UOF incidents since Jan 1, 2017

Administrative Review (e.g. vehicle pursuit, pointing of weapon, policyviolations that if true, would not result in disciplinary action)• Two in Q5: both pointing of weapon (1 firearm and 1 CEW)

Confidential 8

Summary of Where We Are

Confidential 9

• As of March 31, 2018: 68% in Substantial Compliance; 41% require nofurther evaluation

• Into Q6 (ending June 30, 2018) with a total of 32 ERs under review

− 12 scheduled by UCPD to undergo an initial assessment for review

− 20 are being reassessed to ensure ongoing compliance

• Quality evaluation of the Complaints/Internal Investigations will be completedduring Q6

• 57 (21%) Remaining Recommendations that have not yet been assessed/putforward for review by UCPD

• Continue with monthly group check-in, targeted meetings, MADCdevelopment/adjustments

• Next Update to Audit and Risk Management Committee in August 2018

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec

1.1.A Adopt a mission statement that will serve as a foundation and guidepost for its going-forward reforms. - - - - - - - - - -

1.1.BIn developing the mission statement, consider (1) providing for the safety and security of faculty, staff, students and visitors, (2) promotion of concepts of fairness, non-biased policing with minimal intrusion and (3) promotion of service to the broad University community.

- - - - - - - - - -

1.2.A Establish an internal audit or inspectional service unit that reports directly to the Vice President of Safety and Reform. ¡

1.2.B Perform on-going audits for critical areas and functions on a regular cycle to be memorialized in an annual audit plan. ¡

1.2.C Implement a voluntary on-going monitoring function to track each of the reforms outlined in the recommendations and ensure that they are implemented according to the agreed upon schedule. - - - - - - - - - - -

1.3.A Update its policies and procedures to reflect campus law enforcement best practices, and assign ongoing responsibility for ensuring that they are kept current. - - - - - - - - - - -

1.3.B Become certified by CALEA and/or IACLEA.

1.4.A Traffic and pedestrian stops should not be used as a crime fighting tool. Clear guidance by policy and procedure should be given as to when, if ever, off-campus traffic stops are permissible. - - - - - - - -

1.4.BInvoluntary off-campus pedestrian and traffic stops should only be allowed when the officers possesses reasonable suspicion to believe that a pedestrian or motorist is engaged in a criminal, non-driving offense.

¡

1.5.A

Adopt a policy on biased policing, clearly indicating that UCPD officers may not use race, color, ethnicity, or national origin, to any extent or degree, in conducting stops or detentions, or activities following stops or detentions, except when engaging in appropriate suspect-specific activity to identify a particular person or group.

- - - - - - - - - - -

REPORT CARD MATRIX2017 2018 2019

Section 1 - Fundamental Findings Recommendations

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec


Section 1 - Fundamental Findings Recommendations 1.5.B Develop a curriculum and institute training on the biased policing policy including training on implicit

bias and shall deliver such training both to new and existing members of the department. - - - - - - - - - - -

1.6.A Draft and implement a single Use of Force policy that covers what force is permitted and the resulting departmental investigation and review process. - - - - - - - - -

1.6.B The new Use of force policy should emphasize de-escalation and sanctity of life. - - - - - - - - -

1.7.A Arm UCPD officers with CEDs. - - - - - - - -

1.7.B Include a clear policy statement governing the use of CED in the revised use of less lethal weapons policy. - - - - - - - - -

1.7.C Develop intensive training on the use of CEDs and the relevant policies, including scenarios in which the utilization of CEDs is appropriate and those instances where it is not. - - - - - - - -

1.8.AEstablish a protocol for the timely review of every use of force to determine its appropriateness from an administrative point of view and whether or not further investigation, including potential criminal investigation, or discipline is appropriate.

- - - - - - - - -

1.9.A Update hiring policy by requiring diversity applicants throughout the police officer candidate recruitment process. - - - - - - - - -

1.10.A Draft and adopt consistent policies and procedures for the development and approval of all UCPD courses and ensure that all courses are consistent with UCPD mission and philosophy. - - - - - - - -

1.11.A Draft comprehensive Complaint Initiation Policies and Procedures that define the workflow of the different categories of complaints from investigation to adjudication. - - - - - - - - -

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec


Section 1 - Fundamental Findings Recommendations 1.11.B Complaint Initiation Policies and Procedures should prohibit any attempt to dissuade an individual

from filing a complaint, and require officers to report the misconduct of other officers. - - - - - - - - -

1.12.A Recognize the essential nature of the community affairs function within the UCPD and appropriate resources dedicated to it. - - - - - - - -

1.12.B Infuse Community Oriented Problem Solving Policing throughout the fabric of the UCPD.

1.13.A Integrate the data collection systems into one large database that tracks all data.

1.14.AMake maximal use of the criminal justice program at UC and its ICS in order to create the model for community policing that balances the need for safety and security on the one hand with fairness and minimal intrusion on the other.

Office of the Independent Monitor University of Cincinnati Police Department

COMPLIANCE MEMORANDUM

DATE: MARCH 31, 2018 REC. REF. NO.: 1.4.B SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding Prior to the shooting death of Samuel DuBose, traffic stops were being conducted in unprecedented numbers as part of the philosophy of the then newly installed Chief. The Chief failed to understand the potential implications of the initiative given the decision not to aggregate and analyze data on the nature and frequency of such stops. Exiger Recommendation (“ER”) Traffic and pedestrian stops should not be used by UCPD as a crime fighting tool. The potential benefit of such aggressive tactics in terms of crime reduction in the UC setting is modest at best and clearly outweighed by the negative perception of and feelings toward UCPD engendered by such tactics. Clear guidance by policy and procedure should be given as to how traffic stops should be conducted and when, if ever, off-campus traffic stops are permissible. MADC Definition of Compliance Compliance with the above ER will be achieved when the UCPD has achieved compliance with ER 2.1.C. Note: ER 1.4.B is one of the Fundamental Findings that was included in Section 1 as a summarized version of ER 2.1.C and includes identical requirements. Proffer of Compliance from UCPD See Memo of Assessment for ER 2.1.C Data Reviewed See Memo of Assessment for ER 2.1.C

Current Assessment of Compliance

DW – Determination Withheld The Monitor withheld its determination of compliance with ER 2.1.C and therefore has withheld its determination of compliance with this ER. Next Reviews The Monitor will complete its assessment of the UCPD’s compliance with this ER in Q7 ending September 30, 2018.

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec

2.1.A Traffic and pedestrian stops should not be used as a crime fighting tool. Clear guidance by policy and procedure should be given as to when, if ever, off-campus traffic stops are permissible.

2.1.BInvoluntary off-campus pedestrian and traffic stops should only be allowed when the officers possesses reasonable suspicion to believe that a pedestrian or motorist is engaged in a criminal, non-driving offense.

2.1.C To the extent that any safety-related off-campus traffic stops are allowed, particular scrutiny of each such stop should be applied by UCPD Administration. ¡

2.1.D Consider equipping officers with tablets which among other things would enable the electronic capture of stop data through an electronic version of the Field Contact Card.

2.1.E Give officers enhanced training on appropriately dealing with individuals who are stopped.

2.2.A

Adopt a policy on biased policing, clearly indicating that UCPD officers may not use race, color, ethnicity, or national origin, to any extent or degree, in conducting stops or detentions, or activities following stops or detentions, except when engaging in appropriate suspect-specific activity to identify a particular person or group.

- - - - - - - - - - -

2.2.B Develop a curriculum and institute training on the biased policing policy including training on implicit bias and shall deliver such training both to new and existing members of the department. X ¡

2.3.A Develop and implement a protocol for the investigation of complaints of biased policing.

2.3.B Train officers conducting investigations of complaints of biased policing on the protocol to be employed in such investigations. ¡

2.3.C OSR should audit all investigations of complaints of biased policing to ensure that they are being conducted in accordance with establish protocols for such investigations.

Section 2 - Review of Pedestrian and Traffic Stops

REPORT CARD MATRIX

2017 2018 2019

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec

Section 2 - Review of Pedestrian and Traffic Stops

REPORT CARD MATRIX

2017 2018 2019

2.4.A Determine appropriate levels of response and mitigative strategies, including polite explanation, to combat the negative perception created by enhanced response levels.


COMPLIANCE MEMORANDUM DATE: MARCH 30, 2018 REC. REF. NO.: 2.1.C SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding Prior to the shooting death of Samuel DuBose, traffic stops were being conducted in unprecedented numbers as part of the philosophy of the then newly installed Chief. The Chief failed to understand the potential implications of the initiative given the decision not to aggregate and analyze data on the nature and frequency of such stops. Exiger Recommendation (“ER”) To the extent that that UCPD continues to make involuntary off-campus stops, the Office of Safety and Reform, must ensure that such stops are consistent with policy and must continue the collection, aggregation, and analysis of all relevant stop data. Regular meetings should be held among the Office of Safety and Reform, the Chief of Police, and the Director of Public Safety in which the analysis of such data is reviewed to determine whether there exist outlying officers in terms of number of vehicle and pedestrian stops or in terms of any racial disparities among those stopped. MADC Definition of Compliance Compliance with this provision will be achieved when the following is found:

1) UCPD has established regular meetings attended by the Office of Safety and Reform, the Chief of Police, and the Director of Public Safety, in order to analyze all traffic stop data.

2) UCPD has a mechanism to identify outlying behavior inconsistent with UCPD stop policies and procedures and a method for disciplinary action when necessary.

UCPD Proffer of Compliance UCPD has a policy in place to identify outlying behavior inconsistent with UCPD stop policies. This information can be found on pages 4-5 of the Bias Free Policing policy (attached), which details: 1) supervisory review/sign off on all submitted contact cards, 2) corrective measures in response to complaints of biased policing, 3) supervisory (monthly) and administrative (semi-annual) review of stops by officers in order to identify any potential outlying behavior, and 4) corrective measures in response to issues identified by these reviews. In Year 1 of the monitorship, Exiger's review of the Bias-Free Policing Policy in Q2 (ER 12.7.B) noted that at the time there was no requirement for supervisors to document their monthly reviews designed to identify outlying behavior unless such evidence of outlying behavior was discovered, which would require a Form 5 memo through the chain of command. In response and in order to ensure these monthly reviews are properly documented, the UCPD has incorporated the


supervisory review of the following into the monthly individual officer performance reviews required of supervisors: contact card data, traffic stops, suspicious persons contacts, field interviews, arrests, Guardian Tracking entries, body worn camera footage, and (once installed) motor vehicle dash camera footage (see attached for screenshot from Guardian). Through their viewing access to Guardian Tracking, the Monitor team may access all supervisory monthly reviews since the implementation of this documentation system in December 2017. To aid in supervisory review and recognizing that some abnormalities may not be evident in just a one-month snapshot, the Chief has directed the crime analyst to begin producing a monthly report for shift commanders and sergeants (for officers within their command) designed to assist them in identifying any potential outliers or abnormalities that should be further examined and documented per policy. This report will include by officer analysis of: number of incidents, number of contact cards, % dispatched vs. initiated, and racial breakdown of those stopped and will compare the current month’s data to the previous six months. Although recommendation 1.4.B calls for the production of a monthly stop data report, the UCPD is unable to meaningfully analyze these data on a monthly basis due to the small number of traffic stops that occur within a single month. Instead, the UCPD has decided to analyze contact card data on a semi-annual basis, and this administrative review is required on page 5 of the Bias-Free Policing Policy. In the process of preparing the second semi-annual contact card report, initial analyses demonstrated some inconsistencies in the data entry process. In order to ensure data integrity prior to completing the report, the UCPD is conducting a full data audit for the 2017 Contact Card data. The semi-annual report is expected to be provided to the monitor for assessment in Q7. As noted in previous proffer memos, in accordance with the MOU with the City of Cincinnati, UCPD no longer engages in non-emergency traffic stops off campus. Due to the infrequency of these types of stops, regular meetings regarding these data (as recommended by 2.1.C) are not scheduled by the UCPD. Instead the UCPD has laid out a specific procedure for documentation, supervisory review, and command staff notification (to include the Chief of the UCPD, Director of DPS, and VP of OSR) after each off-campus traffic stop is made. This process is specified in Section N (page 12) of the Traffic Enforcement Activities Policy and the Command Staff Situational Notification Policy (both attached). A similar supervisory review process is included for off campus pedestrian stops in the Pedestrian Stops, Field Interviews, and Pat Downs Policy (attached). Finally, it should be noted that training associated with traffic enforcement is part of a separate Exiger Recommendation, 2.1.E. This training is tentatively targeted for September 2018 and that recommendation should be submitted for compliance assessment in Q8. Data Reviewed 1. Traffic Enforcement and Activities (SOP 10.1.100) 2. Bias Free Policing (SOP 4.1.300) 3. Command Staff Situational Awareness Notification (SOP 11.2.800) 4. Semi-Annual Contact Card Report 2017


5. ARMS reports for off campus traffic stop Prior Assessment The Monitor last assessed the UCPD’s compliance with the requirements in this ER in Q3 ending September 30, 2017 finding the UCPD had taken several significant steps towards substantial compliance including specific executive level review of all off-campus traffic stops and appropriate analysis of all stop data. The Monitor found the UCPD in partial compliance as the UCPD had not yet fully implemented the documentation associated with the monthly supervisory reviews of stop data by officer. As of 9/30/17, there had been just four off-campus traffic stops since 1/1/2017. Current Assessment of Compliance DW – Determination Withheld During the current quarter the Monitor reviewed the one off-campus traffic stop that occurred since its prior assessment of this ER and found that it was conducted for a legitimate emergency situation as delineated in the UCPD’s policy and was appropriately reviewed by OSR and UCPD executive staff. The Monitor also confirmed that all off-campus officer initiated activities to include pedestrian stops, are required to be reviewed by a supervisor which includes the Body-Worn Camera (“BWC”) footage. The reviews of off-campus traffic stops are documented on a Form 5 (Interdepartmental Memorandum) whereas the review of the off-campus pedestrian stops are documented within the Axon Evidence system that stores all video footage. In the case of a stop that, for whatever reason, did not include activation of the BWC, a supervisory review would still occur by virtue of the completion of the contact card all of which are reviewed and signed by a supervisor, and are documented via a checkmark in the Guardian Tracking System. The UCPD command staff has indicated that any instance of officer’s failure to activate the BWC are reviewed by executive management and documented on a Form 5 along with the action taken to address the lack of BWC activation. With regard to the department-wide review and analysis of the stop data, as of the end of the current reporting period, the UCPD had not yet submitted its semi-annual report to cover its detailed analysis of stop data from July 1 through December 31, 2017. No outliers were identified during the Monitor’s review of a sampling of contact cards,1 however; given the delayed submission of the Semi-Annual report the Monitor has not yet conducted independent testing or analysis of the data and therefore is withholding a determination of compliance at this time. Next Review The Monitor will complete its assessment of the UCPD’s compliance with this ER in Q7 ending September 30, 2018.

1 The Monitor did note several errors on individual contact cards which were discussed with the UCPD command staff and which is noted elsewhere in this report.


COMPLIANCE MEMORANDUM DATE: MARCH 8, 2018 REC. REF. NO.: 2.1.D SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding Prior to the shooting death of Samuel DuBose, traffic stops were being conducted in unprecedented numbers as part of the philosophy of the then newly installed Chief. The Chief failed to understand the potential implications of the initiative given the decision not to aggregate and analyze data on the nature and frequency of such stops. Exiger Recommendation (“ER”) The University should consider equipping officers with tablets which among other things would enable the electronic capture of stop data through an electronic version of the Field Contact Card. The many other benefits of a mobility platform are discussed elsewhere in this report. MADC Definition of Compliance Compliance with this provision will be achieved when the following is found: 1. UCPD has considered equipping officers with tablets or other means of enabling the electronic capture of stop data. 2. UCPD has a budgeted plan to equip officers with tablets or other means of enabling the electronic capture of stop data in a reasonable time period. Proffer of Compliance from UCPD “The University of Cincinnati, Department of Public Safety has considered acquiring and equipping officers with tablets to assist with efficient field operations. The University is a participant with all Hamilton County, Ohio police agencies in our hardware and software that supports dispatching and data collection of officer activities through the county Regional Crime Information Center (RCIC). During 2016 and 2017, RCIC engaged in an initiative to upgrade/replace our CAD system as well as our in-car computers, or MDC’s. Part of this initiative involved a field test of utilizing tablets in addition to or in place of laptop MDC’s. The determination was made that tablets were not suitable for use in this county, and they are pursuing laptops as a sole replacement. We further inquired into obtaining our own tablets, which would represent a large, unbudgeted expense but learned that RCIC would not support independent tablets or allow us to load our ARMS software onto any device that was linked into RCIC. UCPD has successfully used laptop MDC’s for many years. Finally, the small geography of our jurisdiction allows our officers to return to the station/office (on all of our campuses) to use a hardline computer for data entry without removing the officer far from their assigned areas of patrol. The ARMS system does have a mobile version which would


be needed for use on a tablet; however, the mobile version does not allow for full functionality of the system. If a mobile version were to be implemented, the officers would still need to use a hardline computer to complete their report. For these reasons, we have decided against acquiring tablets for field usage.” Data Reviewed None Current Assessment of Compliance

In Compliance

As described in the UCPD’s proffer of compliance (above in italics), due consideration was given to providing tablets to its officers for the electronic collection of stop data. Based on the explanation provided, the Monitor agrees with the UCPD’s conclusion of being consistent with other Hamilton County law enforcement agencies. Next Review No further review is needed.


COMPLIANCE MEMORANDUM DATE: MARCH 31, 2018 REC. REF. NO.: 2.2.B SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD does not have an implemented policy on biased policing. Exiger Recommendation (“ER”) UCPD’s training on the biased policing policy should include training on implicit bias and such training shall be delivered both to new and existing members of the department. In-service training on the topic shall be developed and delivered annually. MADC Definition of Compliance Compliance with the above ER will be achieved when the following elements are found: 1. UCPD has included a component on implicit bias; 2. UCPD has created a plan to develop, enhance, and deliver these trainings on an annual basis

to new and existing members of the department; and 3. UCPD has appropriately disseminated the existence of its policy against biased policing and

implicit bias trainings. Dissemination should include posting on web-site, posting in all UCPD facilities and integration into training.

UCPD Proffer of Compliance “The University of Cincinnati Police Division implemented a policy regarding bias-free policing in May 2016 that explicitly states that officers may not use race, color, ethnicity, or national origin, to any extent or degree (see page 2 of attached Bias-Free Policing policy). The most recent version of this policy was published and fully disseminated to UCPD personnel in January 2018. Evidence of such is available to the monitor via PowerDMS. As required by the Bias-Free Policing Policy and the Training and Professional Development policy (attached), every new officer hired by UCPD has been trained in Fair and Impartial policing by one of UCPD’s two in-house FIP certified trainers. This 8-hour training course is included in the 80 hours of training required of new hires before going out with a training officer. Their instructor training certificates, Fair and Impartial Policing Lesson Plans and Curriculum, and FIP Scenario Training and Case Study Guidebook were all previously submitted in Q1. The training documentation for these new officers is attached. This policy also requires annual refresher training on bias-free policing on page 4. Although UCPD personnel completed an OPOTA course on Procedural Justice (see 6.7.G), this training did not include content regarding implicit bias. Therefore, the annual training on this topic


required by Exiger Recommendation 2.2.B was not completed department-wide in 2017. Seventeen sworn officers attended the Ohio Attorney General’s online training course on Policing Culturally Diverse Communities (see attached training documentation and course outline). Further, the UCPD training section started communicating with Dr. Bleuzette Marshall of the University of Cincinnati Office of Equity and Inclusion (OEI) in mid-2017 regarding training on implicit bias, diversity, equity, and inclusion, but this training series was not able to be logistically scheduled until 2018 based on the existing training calendar. The OEI is providing a series of training workshops to the UCPD over the course of 2018, and the annual refresher training on implicit bias is scheduled for July 2018 (see attached schedule). In order to prevent missing any required training again in the future, the Training and Professional Development policy now includes a link to a specific list of all training required by policy and the frequency for each, as well as accreditation standard requirements (see attached). The Standards and Strategic Bureau Commander will use this list to ensure the Training Section has scheduled all required training each year. Furthermore, Training Standards is among the in-progress list for topics that the inspections section will annually review. The inspections unit will verify whether all required training was completed and will report the results to the chain of command as part of the inspections process. Data Reviewed None Prior Assessment of Compliance The Monitor last assessed the UCPD’s compliance with this ER is Q1 ending March 31, 2017 and found the UCPD in substantial compliance. The Monitor reviewed the content of the lesson plans for the training and found the module on implicit bias included appropriate case studies to help officers consider situations where their implicit biases could affect their judgment. The training was given by UCPD supervisors who were certified instructors for the course. Current Assessment of Compliance

Non-Compliant

During the current period, the Monitor confirmed that the newly hired officers did attend training as required. As described in the UCPD’s proffer of compliance (above in italics), the annual refresher training related to implicit bias was not scheduled in 2017 which is also specifically required in this ER. Although most of the sworn officers attended an OPOTA mandated course required of all Ohio commissioned officers, titled “Procedural Justice and Police Legitimacy” (covered in our assessment of ER 6.7.G), a review of the course materials found that “implicit bias” was not covered. In actuality the aforementioned OPOTA course presentation scarcely covered bias policing and did not mention diversity. The topic of implicit bias, sometimes referred to as social cognition, refers to the attitudes, stereotypes, and subtle associations that affect individual understanding, actions, and decisions in an unconscious manner. It is said that most people carry some implicit bias and therefore it is critical to understand and recognize how it affects their interactions with the community and police work. As described above in the Prior


Assessment, the FIP training which was attended in October 2015 covered implicit bias extremely well. In response to follow-up discussions with UCPD command staff on this issue, an elective course was identified which was attended by 17 sworn officers through the OPOTA online training system. The course was titled “Policing Culturally Diverse Communities” and based on the course outline provided it covered the topic of diversity very well. The outline also includes the word “bias” once but does not state the context in which it was covered nor does it specifically include content on implicit biases. This latter course was not mandated by the State of Ohio or UCPD but was an elective course which is likely the reason that only 17 of 63 (30%) of the sworn officers attended.1 The Monitor also noted that the course was not listed in any of the training tracking documentation submitted which was purported to include all training attended, annual, elective or otherwise, nor was the curriculum available to determine if the course had been evaluated by the Training Unit to use as the refresher training. Based on the forgoing, the Monitor found the UCPD in non-compliance for 2017. The UCPD could become compliant again for 2018 training requirement if sufficient documentation is submitted demonstrating that greater than 94% of the sworn officers attended refresher training in 2018 as is scheduled with the UC Office of Equity and Inclusion for July 2018. Next Review The Monitor will again review this ER once the UCPD conducts refresher training on this topic, tentatively scheduled for Q7, ending September 30, 2018.

1 The MADC, which have been agreed upon by the UCPD and the Monitor, require that greater than 94% of compliance is required to achieve substantial compliance.


COMPLIANCE MEMORANDUM DATE: MARCH 1, 2018 REC. REF. NO.: 2.3.C SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD does not have a protocol for investigating complaints of biased policing. Exiger Recommendation (“ER”) The Office of Safety and Reform should audit all investigations of complaints of biased policing to ensure that they are being conducted in accordance with establish protocols for such investigations. MADC Definition of Compliance Compliance with this provision will be achieved when:

1) the established annual audit plan (or applicable policy) includes an audit/inspection of all investigations of biased policing to be conducted by the OSR; and, 2) all investigations into complaints of biased policing are audited by the OSR (or his/her designee) to ensure such investigations were conducted in accordance with established protocols.

Proffer of Compliance from UCPD “Investigations of complaints regarding biased policing are referenced in both the UCPD Bias-free Policing Policy and the more general Internal Investigations and Complaints Policy (both attached). Specifically, pages 4-5 of the Bias-Free Policing Policy specifies the complaint process for allegations of profiling or improper biased treatment as well as the investigation and corrective measures for biased policing. Included among the investigation requirements on page 5 in the Bias-Free Policing policy is that:

“The Police Chief or his or her designee will be notified as soon as practical of any complaints of discrimination and/or violations of civil rights. The Police Chief or his or her designee will notify the Vice President for Safety and Reform as soon as practical of any complaints of discrimination and/or violations of civil rights. Upon completion of the investigation of a complaint of this nature, the Vice President for Safety and Reform shall review the investigation to ensure it was conducted in accordance with established protocols for such investigations.”

Similarly, page 7 of the Internal Investigations and Complaints policy includes “discrimination, racial profiling or biased policing” among a list of complaints for which the Chief of Police


receives immediate notification. It follows to say that the Police Chief will notify the Vice President for Safety and Reform of such a complaint, and that the VP for OSR will review the investigation upon its completion (pages 6-7). The UCPD has submitted all citizen and internally generated complaints against UCPD personnel dating from January 1, 2017 to the Monitor for compliance assessment; to date, none have alleged biased policing. Therefore, there are no reviews/inspections of investigations by OSR to submit. The policy/protocol for OSR inspection, however, is in place should such an allegation occur. The monitor will be advised if a complaint of this nature should be received by the UCPD during the period of the monitorship.” Data Reviewed 1. Bias Free Policing (SOP 4.1.300) 2. Internal Investigations and Complaints Policy (SOP 4.2.100) Current Assessment of Compliance In Compliance As described in the UCPD’s proffer of compliance (above in italics), the OSR has a system in place, both by policy and in practice, to ensure an independent review by the OSR, of any complaints alleging biased policing. Having reviewed all 46 complaints that have occurred since the inception of the Monitorship on January 1, 2017, the Monitor agrees that none allege biased policing. Next Review The Monitor will again assess the UCPD’s compliance with this ER only if a complaint of this nature is initiated against a UCPD employee.


COMPLIANCE MEMORANDUM DATE: MARCH 8, 2018 REC. REF. NO.: 2.1.C SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding Both pedestrian and traffic stops have been anecdotally reported on occasion to be over-staffed, with multiple cars and officers responding to otherwise routine stops, which some members of the community described as giving them the impression that they were living in a police state. Exiger Recommendation (“ER”) While officer safety must always be a paramount consideration, the Office of Safety and Reform and UCPD should determine appropriate levels of response and enforce strategies, including polite explanation, to combat the negative perception created by enhanced response levels. MADC Definition of Compliance Compliance with this provision will be achieved when the Office of Safety and Reform and the UCPD have developed, adopted and disseminated (through a Patrol Directive) appropriate levels of response and strategies to mitigate including polite explanation as a means to combat the negative perception created by enhanced response levels. Any complaints implicating this section are resolved appropriately. Proffer of Compliance from UCPD “In order to determine the initial assignment of calls for service, the UCPD’s Emergency Communication Center utilizes the Computer Aided Dispatch automated system, which contains certain thresholds for additional officers and/or a supervisory response, based on the type of call for service and the information gathered as described above. Attached is the hard copy of the electronic “call cards” that the Emergency Communication Center dispatchers use for determining how many officers to send to calls. It is broken down by crimes in progress and report runs for the various types of service calls. The UCPD issued a Patrol Directive in February 2017, which was previously uploaded and reviewed by the Monitor in Q1. This directive includes information regarding officer safety, community perception issues, and decision-making regarding response levels once on scene. As noted by the Patrol Directive, once on the scene it is the decision of the lead officer as to the adequate number of supporting officers needed to address the situation at hand. The Patrol Directive indicates that considerations for the officer’s decision to request additional officers/supervisor or call off backup officers should include, severity of the incident, number and attitude of involved individuals, time and location of incident.


As it pertains to maintaining positive police-community relations and mitigating perceptions of over-enforcement, the UCPD also submits the attached Customer Service Standards policy, published in February 2017 that applies to consensual encounters, non-consensual encounters, and telephone communications. This policy specifically requires the use of a courteous universal greeting and, in the case of a non-consensual encounter, a statement by the officer explaining the reason for the contact. For dispatchers or officers answering telephone communications, it requires the following:

1. Greet the person with an appropriate universal greeting in a courteous manner to include: a. The greeting of the day (i.e. good morning, afternoon). b. Identify themselves by rank (if applicable), name and agency. c. Ask a relevant question (i.e. how may I be of assistance).

2. Obtain complete and accurate information from callers requesting law enforcement or other assistance.

3. Accurately classifying and prioritize requests for assistance. 4. Continuously obtain and accurately relay information which may affect the safety of

responders and/or persons at the scene. All law enforcement officers, security officers, and dispatchers signed the policy and took a test on its contents via Power DMS at that time. The policy was slightly revised in August 2017 and disseminated to all personnel via Power DMS at that time. Evidence of the test and personnel sign offs are available to the monitor via Power DMS. The UCPD has not received any complaints alleging overstaffing of stops since the inception of the monitorship.” Data Reviewed 1. Dispatch Run Types 2. Patrol Directive (previously uploaded) 3. UCPD Customer Service Standards 4.1.400 Prior Assessment of Compliance During Q1 ending March 31, 2017, the Monitor found the UCPD in compliance with this ER as a Procedural Order (“PO”) was disseminated that provided appropriate direction on the appropriate level of patrol response. The UCPD had also indicated that a Dispatch policy was under development to further assist in determining the initial response level when receiving and assigning calls for service. Current Assessment of Compliance

In Compliance

The number of officers initially sent to a call is determined by CAD automated system and not dispatchers. Any additional officers that might respond to a call and/or be released from the scene is determined by the lead officer on the scene or the shift supervisor. During the current period,


the Monitor confirmed there have been no complaints related to an over-response of patrol officers. The Monitor also reviewed the Customer Services Standards policy submitted by the UCPD which contains specific direction to officers and dispatchers for responding to any potential negative response regarding the number of officers on scene at a particular incident. Next Review The Monitor will again assess the UCPD’s compliance with this ER only if a complaint of this nature is initiated against UCPD.

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec

3.1.A Combine SOP 1.3.200, and SOP 1.3.400 with SOP PE 05 into a single Use of Force policy covering when force is permitted to be used as well as the investigation and review process. ¡

3.1.B The new Use of force policy should emphasize de-escalation (see specific language in Report) - - - - - - - - -

3.1.C The use of force policy should define the following terms: Objectively Reasonable, Active Resistance, Passive Resistance, Serious Bodily Injury. - - - - - - - - -

3.1.DInclude a revised use of force continuum or critical decision making model in the use of force policy, which makes clear that the goal of force is to de-escalate any situation, and that only the minimal amount of force necessary should be used to overcome an immediate threat or to effectuate an

- - - - - - - - -

3.2.A The SOP on Use of Force should include a series of prohibitions for officer use, and discharge of a firearm. - - - - - - - - -

3.3.A A clear policy statement governing the use of less lethal weapons should be included in the revised use of force policy. - - - - - - - - -

3.3.BInclude the following definitions in the revised policy to further enhance clarity. Arcing, Activation, Air Cartridge, Confetti Tags, Cycle, Display, Drive Stun, Duration, CED, Laser Painting, Probes, Probe Mode, Resistance, Active Resistance, Passive Resistance, Serious Bodily Injury, Spark Test.

- - - - - - - - -

3.3.C Include a clear policy statement governing the use of CED in the revised use of less lethal weapons policy - - - - - - - - -

3.4.A Consider banning the use of the Kubotan. - - - - - - - - -

3.5.A Establish a system for the collection, storage and retrieval of data regarding uses of force by members of the UCPD.

3.5.B Integrate the use of force data into ARMS.

Section 3 - Review of Use of Force


Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec

Section 3 - Review of Use of Force


3.6.AEstablish a protocol for the timely review of every use of force to determine its appropriateness from an administrative point of view and whether or not further investigation, including potential criminal investigation, or discipline is appropriate.

¡ - - - - - -

3.6.B Provide specialized training to investigators assigned to investigate police uses of force. ¡

3.6.CEngage an independent consultant to conduct any administrative investigation in use of force cases that result in death, officer involved shootings resulting in serious injury or death, or in-custody deaths.

- - - - - - - - -

3.6.DAllow CPD, or the appropriate state agency, to conduct any criminal investigation in cases of use of force resulting in death, officer involved shootings resulting in serious injury or death, or in-custody deaths.

- - - - - - - - -

3.6.EThe identity of the officer(s) directly involved in the discharge of a firearm shall be released to the public within 72 hours except in cases where threats have been made toward the officer(s) involved or the department.

- - - - - - - - -

3.6.F Create a Use of Force Review Board (UFRB) to review all cases where members used deadly force or deployed a CED, or any incident that results in serious injury or death.

3.6.GThe UFRB should be comprised of, at minimum, a high ranking member of UCPD appointed by the Chief of Police, a member appointed by the President of the University, a member of the student body, a patrol officer (or union representative) and a member of the neighboring University of

3.6.H Make the findings of Officer Involved Shooting (OIS) investigation public upon completion - - - - - - - - -

3.7.A Establish training to give all members of UCPD a thorough understanding of the use of force policies and procedures.

3.8.A Hold training for sworn personnel twice annually to include live fire exercises and Reality Based Training (RBT).

3.8.B Crisis Intervention Team Training (CIT) should be a part of both basic recruit and in-service officer training.


COMPLIANCE MEMORANDUM DATE: MARCH 15, 2018 REC. REF. NO.: 3.8.B SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD does not currently employ realistic, scenario-based training. Exiger Recommendation (“ER”) Crisis Intervention Team Training (CIT) should be a part of both basic recruit and in-service officer training. MADC Definition of Compliance Compliance with this provision will be achieved when Crisis Intervention Team Training (CIT) is part of both basic recruit and in-service officer training. UCPD Proffer of Compliance “The UCPD Training Plan (attached), referenced in the Training and Professional Development Policy (attached), requires all new officers be trained in Crisis Intervention within the first 6-9 months of their first year of employment and requires officers to complete refresher training on a biennial basis following the initial training. Page 9 of the Mental Health Response Policy (attached) similarly requires that “Police personnel will receive training on Mental Health Response as part of their initial training and personnel assigned to patrol will receive refresher training at least every two years thereafter.” Although not required by the original Exiger Recommendations, the UCPD’s Annual Training Plan also mandates this training for its dispatchers and makes the training available to its security officers as well. The attached 2017 Continued Professional Training (CPT) spreadsheet and individual certificates shows the in-service training of sworn law enforcement officers, dispatchers, and security officers in 2017. The majority of UCPD’s sworn personnel were trained during 2017 and March 2018. Currently, at the conclusion of Quarter 5, 61 of 63 sworn officers are CIT-trained.1 Two additional sworn officers are scheduled for September and November. However, ten sworn officers that were previously CIT trained are overdue for their every 2 years refresher training. At this time the 4-hour refresher course is expected to occur prior to the end of 2018. It is expected that greater than 94% of sworn officers, who are required to attend this training or its refresher training, will have completed it by Q8. UCPD shift lineup sheets denote all CIT-trained personnel. A sample of line-up sheets may be provided to the monitor upon request.

1 Three UCPD employees hold commissions as sworn officers, but are not currently employed as law enforcement officers. In addition, two UCPD employees are currently completing the Cincinnati Police Department Academy. Neither are included in these total figures.


The two recent apprentice hires will receive 20 hours of Crisis Intervention training as part of their academy training. The academy course materials on this topic are attached. Further, as evidence of their enrollment in the CPD academy, the apprentices’ offer and acceptance letters are attached, which specifically state they will be attending the academy as part of the offer letter. Currently, 10 of 13 dispatchers and 6 of 22 security officers are CIT trained. Due to the limited availability of this course from the outside vendor (Mental Health America of Northern Kentucky and Southern Ohio), the majority of these non-sworn personnel will not be completed until later in 2018, occurring throughout the year on the following dates: May 7-11, September 17-21, and November dates TBD. The contents of the CIT in-service training are attached and include a number of issues specific to student populations. This training, as noted above, is being provided by Mental Health America of Northern Kentucky and Southern Ohio rather than the UCMC because of the quality of previous trainings provided by the vendor to the UCPD and their consistency with best practices and expertise in the subject matter.” Data Reviewed 1. Training Plan 2. Training and Professional Development Policy 3. Mental Health Response Policy 4. 2017 CPT Spreadsheet 5. 2017 CIT Training Certificates 6. CPD Academy Crisis Intervention Training Materials 7. Certificates for those attending March in-service CIT training (forthcoming) 8. In-Service CIT Curriculum including:

CIT: Agitated Psychotic Event CIT: Child and Adolescent CIT: Developmental Disabilities CIT: De-escalation Techniques CIT: Homeless CIT: Suicide CIT: Veteran Affairs CIT: Writing an Effective Hold


Partial Compliance

As described in the UCPD’s proffer of compliance (above in italics), and which was confirmed by the Monitor’s review of the documentation submitted, a large portion of the UCPD sworn officers and many of the dispatchers and security officers received Crisis Intervention Training in 2017. The training curriculum reviewed and attended was found to be sufficient, included realistic,


scenario-based training, and covered topics necessary to ensure officers are equipped as first responders when contacting people who may be undergoing a mental health crisis. While the UCPD has demonstrated that CIT Training is in fact part of the new hire and in-service training program, ten sworn officers were certified prior to 2017 and should have, but did not, receive the required refresher training. The Training Unit has indicated that the planning for the refresher training is underway and will consist of a 4-hour block, but has not yet been scheduled due to the many other competing training priorities during this annual period. The UCPD can obtain substantial compliance once quality in-service/refresher training has been developed, scheduled and attended by officers who have not attended training for over two years. Next Review The Monitor will again report on the status of compliance of this ER in Q8 (Q4 2018).

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec

4.1.A Update policies and procedures to reflect campus law enforcement best practices, and assign ongoing responsibility for ensuring that they are kept current. ¡

4.1.BEstablish a policy and procedure review committee consisting of a cross section of the UCPD and appropriate University resources to assist in updating and developing critical policies and procedures.

4.1.C Work with the newly hired Organization Development Coordinator to fully implement the electronic document management software system. ¡

4.1.D Provide the Coordinator with the resources and support necessary to meet the requirements of his position, and to implement a critical but challenging agenda.

4.1.E Establish a procedure for the review of policies and procedures by appropriate UC personnel including the Vice President for Safety and Reform and General Counsel or his/her designee.

4.2.AEstablish adequate and consistent policies and procedures in several key critical areas including officer supervision and accountability, department transparency, effective diversity recruitment and essential goal setting to develop community trust and partnership.

- - - - - - - - - - -

4.3.A Rewrite Field Interrogations policy to require that stops be constitutional and based upon probable cause and reasonable suspicion criteria.

4.3.B Remove problematic verbiage such as “Persons not fitting the place, time or area.” - - - - - - - -

4.3.C Clarify sections in the procedure on when an officer can conduct a “pat down” for officer safety. - - - - - - - -

4.4.A Rewrite the Trespass Warning to articulate tenets of Constitutional policing as the basis for initiating trespassing encounters and clearly articulate probable cause and reasonable suspicion. - - - - - - - - -

Section 4 - Review of Policies and Procedures

REPORT CARD MATRIX

2017 2018 2019

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec


REPORT CARD MATRIX

2017 2018 2019

4.4.B Remove contradictory language suggesting both that UC is “public property”, yet, “under the laws of Ohio, UC has the right to forbid a person to come onto this property.” - - - - - - - - -

4.5.A Limit the number of off-duty hours officers can work to 20-30 hours in addition to their normal work week. - - - - - - - -

4.5.B Require UCPD approval of any collateral employment to prevent conflict of interests. - - - - - - - -

4.6.A Require that officers complete a police/public safety officers’ bike course, and receive a certification prior to being allowed to deploy on a bicycle. - - - - - - -

4.7.A Rewrite the Unlawful Assemblies policy to include a section on when student assemblies can/should be deemed unlawful. - - - - - - - -

4.8.ARewrite the Plain Clothes Detail policy to address supervisory oversight, notification protocols (UCPD and CPD), when plain clothes details may be utilized and collateral issues to plain clothes deployment.

¡

4.9.A Prohibit the use of Confidential Informants (CIs) except in extraordinary circumstances with clearance at the University reporting level. ¡

4.10.ARewrite the Gangs policy to focus on what specific behaviors constitute a constitutional stop or other law enforcement encounter with a gang member, and to clarify what constitutes gang activity, and how an individual becomes classified as a known gang member.

4.11.A Revise Active Shooter policy so that the section on tactical responses is consistent with Multi-Assault Counter-Terrorism Capability (MACTAC) ¡

4.12.A Update Bomb Threats policy to incorporate the likely motivations of modern bomb threat callers and to ensure alignment with current realities of today’s domestic and foreign terrorist bombers. - - - - - - - -

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec


REPORT CARD MATRIX

2017 2018 2019

4.13.A Make Clery notifications for reportable only for Clery incidents, and make other crime data available on the University’s website

4.14.A Build out a dedicated Emergency Operations Center, designed to facilitate planning and response to both planned and unplanned events in coordination with other federal, state and local agencies. - - - - - - - - -


COMPLIANCE MEMORANDUM DATE: FEBRUARY 20, 2018 REC. REF. NO.: 4.1.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD lacks an effective process for developing and managing new policies and procedures, and reviewing and updating existing ones. Exiger Recommendation (“ER”) UCPD should update its policies and procedures to reflect campus law enforcement best practices, and assign ongoing responsibility for ensuring that they are kept current. MADC Definition of Compliance Compliance with this provision will be achieved when the UCPD develops a process to update its policies and procedures to reflect campus law enforcement best practices, and assigns ongoing responsibility for ensuring that they are kept current. Proffer of Compliance from UCPD “Although the Exiger Final Report made recommendations regarding the development or revision of many specific policies, not all policies fall under a specific Exiger Recommendation (ER). In order to demonstrate implementation of the UCPD processes for developing and/or updating policies and procedures (1.1.400 Written Directive System), the UCPD and Exiger have agreed that all policies that are related to the purview of the monitorship but not covered by a specific ER shall be submitted for compliance assessment with best practice standards under ER 4.1.A. For Q5, the following policies are included:

Policy 2.2.200 Arrest, Processing, Transportation, Interview and Interrogation of Detainees

Policy 15.2.100 Divisional Equipment and Uniform Tracking Policy 2.2.200 Arrest, Processing, Transportation, Interview and Interrogation of Detainees The Arrest, Processing, Transportation, Interview, and Interrogation of Detainees Policy was written by the Director of Public Safety, James Whalen, who has over 30 years of experience in law enforcement. In addition to his expertise and his collaboration with the Chief and Assistant Chief of UCPD, this policy is based on the following policies:

Cincinnati Police procedure 12.600 Prisoners: Securing, Handling and Transporting Cincinnati Police procedure 12.555 Arrest/Citation: Processing of Adult Misdemeanor &

Felony Offenders


Milwaukee Police General Order 2016-58 Citizen Contacts, Field Interviews, Search & Seizure

Arizona State University Police policy Law Enforcement Role & Authority, Arrests & Bookings

Greenville Police policy 1.2.3 Alternatives to Arrest IACP Model Policy on Arrest

Furthermore, a subcommittee of UCPD supervisors (lieutenant and sergeants) and officers reviewed the policy to ensure it matched current practices, referenced the correct UCPD forms associated with processing arrests, and was functional. After the subcommittee met and made recommendations, the policy went through the normal command staff review for final approval. This demonstrates supervisor and officer involvement in the policy development process, which is in accordance with the Written Directive policy. Taken together, this comprehensive approach to policy development ensures that the UCPD’s policy is consistent with best practice standards. The Arrest, Processing, Transportation, Interview, and Interrogation of Detainees Policy was previously submitted to the monitor in Q4. At the time of that assessment, the Monitor noted several areas for needed revisions and found the UCPD to be in partial compliance for the previous quarter. Since then, the monitor worked collaboratively with the UCPD’s Organizational Development Coordinator to ensure the policy meets best practice standards and it is now resubmitted for assessment. It will be disseminated to UCPD personnel after the monitor reviews the revised version of the policy and evidence of such will be provided to the monitor via Power DMS at that time. The policy will be covered during roll call training and tested upon in Power DMS at the time of dissemination. Evidence of both will be provided to the monitor after completion. Policy 15.2.100 Divisional Equipment and Uniform Tracking Although the Divisional Equipment and Uniform Tracking policy is related to ER 10.5.A to “Evaluate and choose an automated commercial off-the-shelf product for tracking of all equipment,” the scope of that ER was limited to the selection of equipment tracking software only. The monitor found that ER in substantial compliance in Q3. Therefore, the policy subsequently developed is submitted for assessment under 4.1.A. This policy was developed through the combination of: 1) a review of other agency policies, 2) the PMI Evidence Tracker website and user training manual (attached), and 3) the Power DMS command staff workflow / review process (screenshot attached). In addition, a Weapons Tracking Form and Uniform Request / Distribution form were created to align with the new policy and links to the forms are embedded in the policy. Both forms are attached. The Divisional Equipment and Uniform Tracking policy will be disseminated to UCPD personnel after the monitor reviews it; evidence of such will be provided to the monitor via Power DMS at that time.”


Data Reviewed 1. Policy 1.1.600 Obeying Lawful Orders 2. Policy 2.2.200 Arrest, Processing, Transportation, Interview and Interrogation of Detainees 3. Policy 7.2.100 Weapons Management 4. Policy 11.2.800 Command Staff Situational Notification 5. Policy 1.1.400 Written Directive System (reference only) Prior Assessments of Compliance During Q1 ending March 31, 2017, the Monitor found the UCPD in compliance with this ER as the UCPD had assigned the Organizational Development Coordinator (“ODC”) responsibility of policy development, revision, and management to ensure the UCPD policies meet best practice standards. The Monitor and the UCPD agreed that reviews of continuous implementation would occur throughout the Monitorship based on policies submitted. During Q4, ending December 31, 2017, the UCPD submitted several polices that were well written and were clearly based on appropriate model policies. However, one of the policies submitted, the Arrests policy, required more substantive revisions and had not yet been disseminated as of the end of that reporting period. Consequently, the Monitor found the UCPD in partial compliance at that time. Current Assessment of Compliance

Partial Compliance

During the current quarter the UCPD again submitted several policies for assessment. The Monitoring Team and the ODC collaboratively made a few minor adjustments to ensure the policies met best practice standards and are consistent with comparable policies within the law enforcement community. The Arrests policy was also submitted but not until later in the reporting period and while most of the previously identified revisions had been addressed, a few remained and the UCPD was not able to fully disseminate the policy prior to the end of the reporting period. The UCPD intends to create a training /testing function as part of the dissemination process which will be included in the next assessment. The Monitor confirmed that the other policies submitted were disseminated to appropriate personnel; however due to the status of the Arrests policy the Monitor found the UCPD in partial compliance at this time. Next Review The Monitor will again assess the UCPD’s compliance this ER in Q6 ending June 30, 2018.



DATE: FEBRUARY 20, 2018 REC. REF. NO.: 4.1.D SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD lacks an effective process for developing and managing new policies and procedures, and reviewing and updating existing ones. Exiger Recommendation (“ER”) Provide the [Organizational Development] Coordinator (“Coordinator”) with the resources and support necessary to meet the requirements of his position, and to implement a critical but challenging agenda. MADC Definition of Compliance Compliance with this recommendation will be achieved when the Coordinator is provided with the resources and support necessary to meet the requirements of the position (clerical, special assignment from patrol, etc.), and to implement a critical but challenging agenda. Proffer of Compliance “The Department of Public Safety leadership has carefully divided up the Exiger Final Report recommendations related to policy development and revision to personnel with varied expertise throughout the organization as to not overload any one individual. The Organizational Development Coordinator, however, serves as the final reviewer and publisher of the approved policies. The department also implemented policy committee meetings that include a cross section of agency personnel to assist in updating and developing policies. A list of recent policy committee meetings is provided below.

12/15/17 John, Chief Herold (Promotion Policy) 11/21/17 John, Captain Carter (Early Intervention Policy) 11/14/17 John, Lt. Barge (In-Car Camera Policy) 10/31/17 John, Nicole Smith, Christie Joslin, Ashley Buten (Records Policy) 10/25/17 John, Dawn Miles, Lt. Gutierrez (Training and Professional Development

Policy) 10/20/17 John, Lt. Barge (In-Car Camera Policy) 10/17/17 John, Nicole Smith, Christie Joslin, Ashley Buten (Records Policy) 10/12/17 John, Lt. Barge (In-Car Camera Policy)


9/27/17 John, Chief Carter, AC Herold, Capt. Carter, Capt. Smith, Captain Thompson, Lt. Hoffman, Sgt. Maxwell, Lixuan Zheng (IT support) (Early Intervention Policy/Guardian Tracking)

9/18/17 John, Sgt. Weibel, PO Lori Cronin, SO Antione Frye (Uniform Policy) 9/13/17 John, Chief Carter, AC Herold, Capt. Carter, Capt. Smith, Captain Thompson,

Lt. Hoffman, Sgt. Maxwell, Lixuan Zheng (IT support) (Early Intervention Policy/Guardian Tracking)

To further enhance the agency’s ability to conduct policy and procedure research into best practices in policing, UCPD has continued its subscription to IACPNet (see attached documentation). The department also hired a Training Consultant to perform a variety of professional and administrative management support duties involving assessing, coordinating, developing, researching, and special projects for the Department of Public Safety training program unit. This has reduced the burden of training requirements on the ODC. Finally, the Chief and Assistant Chief of Police have implemented meetings twice a month with the Organizational Development Coordinator to review and update the status of policy revisions and to ensure the Coordinator is receiving the cooperation, resources and support throughout the organization to implement the policy, IACLEA accreditation and training initiatives.” Data Reviewed Receipt for Subscription to IACPNet Prior Assessment of Compliance During Q1 ending March 31, 2017, the Monitor found the UCPD in compliance with this ER. The UCPD policy development processes clearly illustrated that the ODC was being provided support and adequate resources.

Current Assessment of Compliance In Compliance

As described in the UCPD’s proffer of compliance (above in italics), the Organizational Development Coordinator (ODC) has been charged with managing the development, review, and dissemination of its policies, along with the implementation of the International Association of Campus Law Enforcement Administrators (ICALEA) accreditation program. While no additional staff are directly assigned to the ODC, various support mechanisms are in place such as regular meetings with the UCPD executive staff, the use of online resources, the use of model policies provided in its subscription to International Chiefs of Police (IACP), and the most recently implemented collaborative process between the ODC and the Monitoring team. All told, these processes have proven to be effective in ensuring that UCPD policies are developed with the best and most current law enforcement practices available.


Next Review The Monitor will conduct its final assessment of the UCPD’s compliance with this ER during Q12 ending December 31, 2019.



DATE: FEBRUARY 20, 2018 REC. REF. NO.: 4.6.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD’s Bicycle Assignment & Maintenance policy (SOP 41.1.401), which allows officers to deploy bikes for both patrol and general transportation, is not consistent with best practices. Exiger Recommendation (“ER”) UCPD should require that officers complete a police/public safety officers’ bike course, and receive a certification prior to being allowed to deploy on a bicycle. MADC Definition of Compliance Compliance with this provision will be achieved when: 1. The revised Bicycle Assignment and Maintenance policy represents best practice including a

requirement that officers complete a police/public safety officers’ bike course and receive a certification prior to being allowed to deploy on a bicycle; and,

2. Verification that only certified officers are assigned to bike patrol. Proffer of Compliance from UCPD “The University of Cincinnati Police Division submitted an updated version of its policy “Bicycles: Assignments, Use and Maintenance” during the first quarter of the monitorship. It is being resubmitted for annual reassessment in Quarter 5 and the most recent version of the policy is attached. The policy includes the requirement for completion of a police mountain biking course prior to being permitted to ride a bicycle on patrol. The instruction required for certification is through the International Police Mountain Biking Association (IPMBA), which has been in existence since 1991 and is considered one of the top organizations to train police for bike patrol. Certified bicycle officers are noted in the far right column on each shift’s line-up sheets (see attached). Officers actually assigned to bicycle patrol are noted in the “Bike” column. UCPD held an IPMBA training in July 2017, taught by in-house IPMBA certified instructor Jeff Polly, to certify five additional personnel as bike officers. The training sign-in roster is attached. Although the IPMBA certification does not require a refresher training, UCPD policy includes the requirement for refresher training “Every two years from the date of certification” (attached policy, page 2). Unfortunately, this training was not able to be conducted in 2017 due to the in-house instructor being on medically restricted duty following surgery. The in-house instructor is currently developing an 8-hour in-service refresher bike course for all IPMBA certified officers.


This should be completed by Q6. The UCPD is also sending a second officer, Andrew Mueller, to get IPMBA certified as an instructor at the beginning of June 2018. Data Reviewed 1. Bicycles: Assignments, Use and Maintenance policy 9.2.101 2. Certificates from certified officers 3. Shift line-up sheets from the dates requested by the monitor 4. IPMBA training sign-in roster, July 2017

Prior Assessment of Compliance During Q1 ending March 31, 2017, the Monitor found the UCPD in compliance with this ER as the UCPD’s revised bicycle patrol policy addressed the requirements of the ER and adequately dealt with training and deployment issues.


During the current period the Monitor reviewed the shift line ups for a period spanning several weeks along with certification documentation, and confirmed that only certified bicycle officers, who are those who have completed the certification course created by the International Police Mountain Bike Association (“IPMBA”), were deployed on bicycles. Next Reviews No further review of this ER is needed.


COMPLIANCE MEMORANDUM DATE: MARCH 31, 2018 REC. REF. NO.: 4.11.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD’s Active Shooter policy (SOP 46.1.10) is very general in its scope and not consistent with best practices. Exiger Recommendation (“ER”) This policy should be revised so that the section on tactical responses is consistent with best practices. MADC Definition of Compliance Compliance with this provision will be achieved when: 1) UCPD rewrites its policy on Active Shooters; 2) The updated policy has been rewritten so that the section on tactical responses is consistent with best practice; and 3) Adequate training on active shooter has been completed and documented. Proffer of Compliance from UCPD “Due to the significant amount of training courses that were scheduled for 2017, the UCPD was not able to complete the Active Shooter training that is scheduled to occur annually according to the UCPD Training Plan (see attached) and that is required on page 4 of the Active Threats Policy (attached). The UCPD, did however, devote considerable effort during 2017 to research best practice training options on this topic and has prioritized the decided upon training for 2018. As part of doing our due diligence in researching the best training to implement department-wide, the Training Section has been working with Eastern Kentucky University, Texas State University, and Ohio State University. Two courses were explored as the primary options: Advance Law Enforcement Rapid Response Training (ALERRT) and Single Officer Response to an Active Threat (SORAT). Based on the initial Course Consideration Analysis (see attached), which included a review of available course material (see attached), it was determined that the UCPD would pursue ALERRT training first. SORAT may be considered for inclusion in the UCPD training curriculum at a later date and two UCPD personnel attended SORAT training in February 2018 (training certificates attached). The Training Section Supervisor attended the ALERRT course in June 2017 in order to evaluate it (certificate attached). The corresponding Vendor Course Review and New Course Approval forms are attached as evidence of the evaluation and approval process required by the Training


and Professional Development Policy (also attached). UCPD sent two instructors to ALERRT Train-the-Trainer certification in October 2017 (certificates attached). Additionally, two instructors attended Simunition Trainer Certification because simunitions are used during role play scenarios in the ALERRT training. The ALERRT training requires two full work days and the Training Section needs to ensure that the recently ordered safety and training equipment for the course arrives prior to confirming the training schedule. Currently, the most expedited training schedule possible has this course scheduled as follows as part of a 40 hour in-service training that includes other topics as well:

1. ICAT (also referred to as CDM Training) – 2 days 2. ALERRT Level 1 – 2 days 3. CPR – half day 4. Simulator Training and Weapons Handling – half day

Proposed In-Service Dates (subject to change based on arrival of equipment, availability of trainers):

4/30-5/4 7/30-8/3 5/14-5/18 8/13-8/17 6/18-6/22 8/27-8/31 6/25-6/29 9/10-9/14 7/23-7/27 10/8-10/12 It is anticipated that greater than 94% of UCPD personnel (including ULEOs, security officers, and dispatchers) will complete this training by November 2018. The monitor team is invited to attend this training if desired. During Quarter 5, the UCPD hosted, with the Department of Homeland Security, a tabletop exercise on active threat/shooter scenarios (see attached invitation/agenda). This was attended by 16 sworn and non-sworn personnel from UC Department of Public Safety and the Police Division (see attached sign-in roster with names and affiliation) as well as personnel from other universities located in Ohio. Finally, the UCPD also has plans to conduct ongoing simulator sessions (see above schedule), room clearing drills, and active shooter drills during the remainder of 2018. Evidence of these additional training exercises can be provided to the monitor upon their completion (likely in Quarter 8).” Data Reviewed 1. UCPD Training Plan 2. Active Threats Policy 3. Training and Professional Development Policy 4. Course Consideration Analysis for ALERRT and SORAT 5. Vendor Course Review for ALERRT 6. New Course Approval Form for ALERRT 7. ALERRT Level 1 Manual


8. SORAT Training Curriculum 9. Instructor Certifications: ALERRT 10. Instructor Certifications: Simunition Training 11. Certificates of Completion: SORAT 12. ALERRT attendance records 13. DHS Table Top Exercise 2/12/18 Invitation and Agenda 14. DHS Table Top Exercise 2/12/18 sign in roster Prior Assessment In its prior review in Q1 ending March 31, 2017, the Monitor found the UCPD in compliance because its revised policy enumerated the guidelines and philosophies employed as best practice throughout the profession and sufficient documentation was submitted indicating some training was provided. The Monitor noted and the UCPD agreed, that the training provided (the viewing of a video alone) was inadequate and the department should devise a way to conduct live training scenarios in partnership with other agencies that may be involved.

Current Assessment of Compliance Partial Compliance

As mentioned above in the Monitor’s prior assessment, the UCPD has ensured that its policy on Active Shooter response is consistent with the guidelines and philosophies that are employed as best practice throughout the profession and was disseminated to all UCPD personnel. However, for any policy to be effectively implemented adequate and appropriate training must follow the publication of the policy. As agreed upon by the UCPD and the Monitoring team, the MADC and its policy require annual training on this topic. The frequency and type of training needed is completely dependent on the content of the policy. Given today’s environment, it is extremely important that sworn officers at a minimum, and security officers and other important players from the campus community whenever possible, have annual training on this topic. All officers who could be called upon to respond to an active shooter incident should receive training in critical tasks, such as assessment of an active shooter scene, room entry techniques, recognition of explosive devices, and the roles of contact teams, evacuation and perimeter teams. As was stated in the Monitor’s prior assessment, the importance of including live training scenarios in a safe environment and in partnership with other agencies that may be involved in this type of incident, cannot be understated. Strong policies and training can help to ensure that, despite the rapidly changing dynamics, an active shooter situation does not result in the worst case scenario. Experts strongly recommend that police agencies also conduct advanced training for active shooter incidents that includes realistic training in the use of firearms in an active shooter incident. As described in the UCPD’s proffer of compliance (above in italics) while research was conducted to ensure that quality training will be delivered in 2018, the UCPD did not conduct Active Shooter training in 2017 even though it is an annual requirement per the UCPD Annual Training Schedule and also based on best practices. The UCPD has indicated that the reason was due to the significant amount of training courses on other topics that were scheduled in 2017. While formalized training was not provided, significant steps were taken towards compliance policy, and therefore the Monitor found the UCPD in partial compliance for this assessment.


Next Review The Monitor will assess the UCPD’s compliance with this recommendation again in Q6 ending June 30, 2018, and report any progress in this area until substantial compliance is achieved.



DATE: FEBRUARY 10, 2018 REC. REF. NO.: 4.13.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD has historically made Clery1 notifications for non-Clery-reportable off-campus crimes. Exiger Recommendation (“ER”) UCPD should only make Clery notifications for reportable Clery incidents. Other crime data should be made available on the University’s website. MADC Definition of Compliance Compliance with this provision will be achieved when the UCPD procedures reiterates that Clery notifications will only be made for appropriately "Timely Warning" Clery incidents; and crimes which do not require "Timely Warning" are made available on the University's website; and, the UCPD's incident reporting is consistent with its policy and procedures. Proffer of Compliance “The UCPD Timely Warning and Emergency Notifications SOP was revised slightly since the Q1 assessment of ER 4.13.A. The updated version of the policy is attached. It clearly states that Clery notifications will only be made for appropriate “timely warning” Clery incidents on pages 2-3. This policy was fully disseminated to UCPD personnel and evidence of such is available to the monitor via Power DMS. This policy specifically references the University of Cincinnati Jeanne Clery Disclosure of Campus Safety Policy and it was revised since Q1 as well; therefore, that updated policy is also attached. The Department of Public Safety’s link to Clery safety notices can be found here: http://www.uc.edu/publicsafety/clery/safety-notices.html; it includes a link to an archive of Clery notices by month at: https://listserv.uc.edu/scripts/wa.exe?A0=SAFETYNOTICE. The website link for a listing of crimes which do not require timely warning, and which is searchable by date range, is available at:

http://www.uc.edu/webapps/publicsafety/policelog2.aspx. Also attached is the 2017 Annual Security and Fire Safety Report, which is required by the Clery Act, and released annually on or before October 1st. This report contains campus crime and fire statistics for the previous three 1The Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act or Clery Act, signed in 1990, is a federal statute codified at 20 U.S.C. Sec 1092(f), with implementing regulations in the U.S. Code of Federal Regulations at 34 C.F.R. 668.46. The Clery Act requires all colleges and universities that participate in federal financial aid programs to keep and disclose information about crime on and near their respective campuses. Compliance is monitored by the United States Department of Education, which can impose civil penalties up to $35,000 per violation, against institutions for each infraction and can suspend institutions from participating in federal student financial aid programs.


years on all UC campuses, as well as descriptions of: UC Public Safety services; Fire Policies; Safety Equipment; and University Safety Programs.”

Data Reviewed 1. UCPD Policy 16.3.200 Timely Warning and Emergency Notifications, updated 3/23/17 2. University of Cincinnati Jeanne Clery Disclosure of Campus Safety Policy 3. 2017 Annual Security and Fire Safety Report Prior Assessment of Compliance During Q1, ending March 31, 2017, the Monitor found that the UCPD appropriately provided Timely Clery Act alerts and notifications, and posted crime information for public availability on the UC’s Public Safety website.


The Monitor reviewed both the UCPD’s and the University’s revised policies covering the Clery Act notification requirements. The Monitor confirmed consistency with the reporting requirements and specific crimes listed in the Clery Act. The Monitor also reviewed the UCPD’s crime statistics for 2017 as contained in the UCPD’s Annual Security and Fire Safety Report as compared to the Safety Alert notifications contained on the UC’s website for the same time-period and found no inconsistencies. Next Review The Monitor will conduct its final assessment of the UCPD’s compliance with this ER during Q9 ending March 31, 2019.

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec

5.1.A Update hiring policy by requiring diversity applicants throughout the police officer candidate recruitment process.

5.1.B Partner with well-established minority groups who will share and forward the UCPD’s recruitment advertisements. - - - - - - - - - -

5.2.A Work with officers, student population, and community members to craft a UCPD mission statement that states the reason that UCPD exists, what IT does, and reflects its basic philosophy. - - - - - - - - - -

5.2.B Develop a strong employer brand that will contribute to its becoming the law enforcement employer of choice in Cincinnati.

5.3.A Expand the search for police officer candidates by partnering with well-established groups to share and forward recruitment advertisement to a broader community network. - - - - - - - - - -

5.3.B Target all groups including women, Hispanic, Asian, AA and LGBTQ both in the community and on campus.

5.3.CIncrease recruitment efforts among the more diverse pool of UCPD campus security officers and other university employees who serve in different campus departments who may have demonstrated commendable performance and good judgment.

- - - - - - - - - -

5.3.D Ensure that recruitment campaigns reflect UCPD’s commitment to diversifying and market values like community engagement, partnerships, shared responsibility for crime prevention, etc.

5.3.E Leverage, to the greatest extent possible, its family tuition payment program, in an attempt to bring seasoned, diverse, mission-appropriate candidates into the recruitment mix. - - - - - - - - - -

5.4.A Revise and update the current hiring policy to a true best practice recruitment and selection plan that acknowledges the need for diversity and sets diversity as a goal.

Section 5 - Review of Officer Recruitment, Hiring, Promotion, and Retention

REPORT CARD MATRIX

2017 2018 2019

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec


REPORT CARD MATRIX

2017 2018 2019

5.5.A Explore the adoption of the Community Collaboration Model for recruitment. - - - - - - - - - -

5.5.B Ensure that recruitment outreach is inclusive of all on and off campus communities including the LGBTQ community. - - - - - - - - -

5.5.C Carefully select and train officers who attend recruiting events like career fairs.

5.5.D Establish recruitment ambassadors, comprised of University staff, students and community members, that will work with officers and on their own to help recruit applicants.

5.5.E Work toward making recruitment part of UCPD officers’ regular interactions with the community. - - - - - - - - -

5.6.A Track the performance of former Security Officers to assess any impact of the streamlined hiring process. - - - - - - - - - -

5.6.B Use lateral and retired officers, after careful screening to ensure that their qualifications and background are consistent with the mission and philosophy of UCPD. - - - - - - - - -

5.6.C Consider a relocation bonus for lateral hires. - - - - - - - - - - -

5.6.DBuild a process that gives priority to Cincinnati residents (1) at the beginning of a career or (2) in transition from a previous career and whose career aspirations are consistent with the mission and philosophy of UCPD.

- - - - - - - - - -

5.6.E Actively work with local high schools to identify and work with young people who may aspire to a career consistent with the UCPD mission and philosophy.

5.6.F Consider creating a UCPD Police Cadet program and a student intern program.

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec


REPORT CARD MATRIX

2017 2018 2019

5.6.G Consider offering a free Candidate Applicant Preparation Program

5.7.AEnsure that the annual evaluation process proposed in the Diversity Plan include the collection of data at every step, test, and exclusion point in the hiring process, including those who voluntarily drop out of the process. Use this data to continuously improve the hiring process.

5.8.A Consider developing and providing support mechanisms for all applicants to reduce the number of no shows and failures.

5.8.BEnsure that the proposed suitability assessments of the applicants to the agency is preceded by the adoption of a roadmap to change existing culture to the extent necessary to align it with that of the newly defined mission of the department.

5.8.C Screening of candidates with prior law enforcement experience. - - - - - - - - -

5.8.D The panel interview should be conducted by a diverse panel.

5.8.E Review of contractor process for bias and mission.

5.9.A Define the desired traits and qualifications for a supervisor, and those should be reflected in assessment center exercises, interview questions and scoring protocol.

5.10.AEnsure that the process for promotion is evaluated annually by the Chief, Assistant Chief and Lieutenants, and consider annual review of both the promotion and career development process by both the Chief and the Director of Public Safety

5.11.A Use students and community members in the assessment center exercises and in the interview processes.

5.12.A Update the promotional policies and procedures to reflect the position of Sergeant. - - - - - - - - -

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec


REPORT CARD MATRIX

2017 2018 2019

5.13.A Select a turnover/attrition metric to identify and react to deviations from the expected rate.

5.13.B Enhance the recruitment and hiring process to ensure that candidates have proper expectations and are the right fit the job.

5.13.C Conduct, maintain and analyze exit interviews in order to better understand any deviations from the expected attrition rate.



DATE: FEBRUARY 26, 2018 REC. REF. NO.: 5.10.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding Current procedures for review of promotion decisions and the promotion/ career development process are inadequate. Exiger Recommendation (“ER”) UCPD should ensure that as required by the current SOP, the process for promotion is evaluated annually by the Chief, Assistant Chief, and Lieutenants. Additionally, UCPD should consider annual review of both the promotion and career development process by both the Chief and the Director of Public Safety. MADC Definition of Compliance Compliance with this provision will be achieved when:

1) In practice, the process for promotion is evaluated annually by the Chief, Assistant Chief and Lieutenants;

2) UCPD gives meaningful consideration to requiring an annual review of both the promotion and career development process by both the Chief and the Director of Public Safety.

UCPD Proffer of Compliance “The Law Enforcement Supervisor promotional process (SOP 3.1.300) was originally submitted to the monitor for assessment in Q3. The Monitor withheld its determination of compliance during this period due to the revisions needed to ensure the policy is consistent with best practices. During Q4, the Monitor and the UCPD command staff and Policy Review Committee collaborated on these revisions and the UCPD resubmitted the Law Enforcement Supervisor Promotional Process for compliance assessment. At that time, the monitor approved the content of the policy (including the annual evaluation of the process for promotion), but found the UCPD in partial compliance because the revised policy had not yet been disseminated to UCPD personnel. The policy is now fully disseminated to UCPD personnel and evidence of such is available to the monitor via Power DMS. In addition, since the Monitor’s Q4 assessment of this ER, the UCPD has completed the promotional process for one lieutenant position and one sergeant position. The documentation for each of these promotions is attached.”


Data Reviewed 1. Law Enforcement Supervisor promotional process (SOP 3.1.300) 2. Lieutenant Promotional Process Documents 3. Sergeant Promotional Process Documents

Prior Assessment of Compliance During Q4 ending September 30, 2017, the Monitor found the UCPD in partial compliance with this ER as the policy had not yet been fully disseminated. Current Assessment of Compliance

In Compliance

During the current quarter, the Monitor confirmed that the policy has been fully disseminated and reviewed the promotion documents submitted by the UCPD. The documents support that the process being followed is on par with best practices as compared with other law enforcement organizations, and appear to be fair and consistent in the manner administered. The Monitor will continue to review the examination process and promotions made during the monitorship period. Next Review The Monitor will conduct a final assessment of the UCPD’s compliance with this ER in Q9 for the period ending March 31, 2019.

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec

6.1.A Draft and adopt consistent policies and procedures for the development and approval of all UCPD courses and ensure that all courses are consistent with UCPD mission and philosophy.

6.1.B Ensure appropriate oversight of outside training to ensure it is consistent with Department Mission, Vision and Values. ¡

6.1.C Require proper tracking, and evaluation of all courses and instructors. ¡

6.1.D Require instructors to attend a certified instructor development course.

6.1.E Ensure training is consistent with officer tasks and competencies to successfully serve in an urban and campus environment in a manner consistent with Department Mission, Vision and Values.

6.1.F Establish and maintain a “lessons learned” program.

6.1.G Establish a Training Committee responsible for review of training policies and procedures, curricula development and course delivery.

6.1.H Ensure that training opportunities are available to all employees both sworn and unsworn. ¡

6.2.A Locate the training office within headquarters and create a state of the art on-campus learning environment by identifying a professional setting for in-service training.

6.3.A Develop a portion of the 80-hour class in an e-learning format, to be delivered immediately upon swearing in, so as to allow for appropriate orientation before the commencement of patrol functions.


Section 6 - Review of Training

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec


Section 6 - Review of Training 6.4.A

Develop introductory curricula, with time allotment and method of delivery (e-learning versus classroom) for the Clery Act; Mission, Vision and Values of UCPD; and community relations for inclusion in orientation training.

6.5.ADesign courses to specifically meet unique training needs including courses addressing the unique intersection of urban and university policing, and training designed to promote effective interactions with diverse populations.

6.6.A Build on the recommendations of this report relative to needs assessment and conduct a formal review of training, to be repeated on an annual basis.

6.6.BDevelop an annual training plan consisting of goals and strategy based on an annual formal needs assessment, with input from the Chief of Police, a training committee comprised of UCPD personnel, training unit officer-in-charge, and the community.

6.7.ADevelop as part of the annual training plan a mandatory training curriculum in modular format, to be reviewed and modified annually, including the state-mandated training as well as those courses which are determined to be best suited for UCPD-mandated annual training.

6.7.BInfuse the curriculum developed with elements of community policing, including a clear and unified message as to the UCPD’s commitment to community policing, as well as with critical thinking and problem solving skills training throughout.

- - - - - - -

6.7.C Develop a series of elective courses in different relevant subject matter areas all of which would have to be completed over a three-year period.

6.7.DConsider courses for the mandatory training that include updates on trends and innovations in both municipal and university policing, an update on Ohio criminal law, a use of force update including de-escalation techniques, community and problem solving policing updates, and anti-bias training.

6.7.EElective courses should include: Community-police relations; Building partnerships with communities both on and off campus; Critical thinking and problem solving; Ethics and Integrity; Diversity; Biased policing; Substance Abuse; Date rape; Leadership; De-escalation skills through

6.7.F Determine the appropriate split of total mandatory annual training hours between mandatory and elective courses.

6.7.G Increase diversity and biased policing training and require these subject to be recurrent training annually.

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec


Section 6 - Review of Training 6.7.H Centralize and maintain records of all training in an electronic format which becomes part of an

Officer’s personnel package ¡

6.8.A Develop a process by which UCPD develops its curricula.

6.9.A Establish a lessons learned program, derived from UCPD uses of force, post-incident debriefings, employee suggestions, personnel complaints and case law updates.

6.10.A Develop a list of tasks and skill competencies expected of an FTO.

6.10.B Create a selection process to assess whether an applicant has the skills necessary to train new officers.

6.10.C Ensure that all FTO’s support the Mission, Vision and Values of UCPD and will be a strong role model for new employees.

6.10.D Ensure that the selection process includes a detailed review of the disciplinary and merit file of the candidate.

6.10.E Ensure that there is a policy that requires a timely suitability review of any FTO in the case of a sustained complaint involving that FTO.

6.11.A Require instructors to be OPOTC Certified Instructors.

6.12.ARequire all courses taught by UCPD instructors to have written lesson plans that include clearly stated, realistic performance objectives and learning activities that utilize multiple learning modalities.

6.12.B Base the training approach on the tenets of adult education, promoting decision-making and critical thinking.

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec


Section 6 - Review of Training6.12.C Develop problem-based scenarios and case studies that allow the student to apply problem solving

skills & knowledge of diverse populations.

6.12.D Require curriculum review before a class is taught. ¡

6.12.E Observe instructors and rate performance.

6.12.F Survey students relative to the performance of their instructor.

6.13.A Ensure that community relations issues are included in use of force courses and that unique campus life issues are included in the defensive tactics course.

6.14.ARequire by policy that all non-UCPD training be reviewed and approved prior to authorizing attendance at such program, and that a syllabus of such training be obtained for inclusion in the attending employee’s file.

¡

6.15.A Ensure that the training lieutenant is devoted primarily, if not exclusively, to all of the tasks attendant to training. - - - - - - - - - -

6.15.B Re-establish the Training Review Committee under the direction of the training lieutenant and include a member from the university and two members from the community.

6.15.C Ensure that an annual Continuing Education Plan and Learning Needs Assessment is conducted.

6.15.D Review, approve, and maintain the curriculum of every outside course approved for attendance by a UCPD officer. ¡

6.16.A Obtain a Learning Management System (LMS) to track all training records, retain expanded course outlines and lesson plans, allow for automated employee training requests and approvals. ¡

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec


Section 6 - Review of Training6.16.B Use best practice templates to design training, evaluate training delivery and instructors. ¡

6.16.C Complete regular assessments of courses and training delivery. Ensure curricula includes relevant and realistic officer tasks and competencies. ¡

6.16.DTraining Unit lieutenant should approve all internal courses and lesson plans, and approve all outside courses prior to employees being allowed to attend to ensure consistency with UCPD policies, procedures, and agency mission, vision and values.

6.17.A Identify the actual training budget for equipment and off-site training each year and hold the department accountable for working within its training budget.

6.18.A Develop a policy with respect to the selection of instructors and for the evaluation of their performance.

6.19.A Develop a policy which charges the training lieutenant with mandatory attendance (either by himself or an appropriate designee) of training in order to evaluate, in writing, its effectiveness.

6.20.AExtensively collaborate with the University on issues of training and should consider the creation of a Community-Police Academy for surrounding communities and a Student Community-Police Academy for campus communities.

6.21.A Collaborate with CPD on issues of training

6.22.A Utilizing the Claremont Campus OPOTC-certified Police Academy as its own internal academy where sponsored/hired cadets could attend.


COMPLIANCE MEMORANDUM DATE: MARCH 30, 2018 REC. REF. NO.: 6.4.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding Several critical areas appear to be missing from the orientation training such as community relations, the Clery Act, and a statement of mission, vision, and values of UCPD. It is unlikely that the 80-hours of training provide sufficient time to cover the additional subjects that new hires should receive. Exiger Recommendation (“ER”) Develop introductory curricula, with time allotment and method of delivery (e-learning versus classroom) for inclusion in orientation training; curricula should include the Clery Act; Mission, Vision, and Values of UCPD; and community relations. MADC Definition of Compliance Compliance with this recommendation will occur when: 1) UCPD develops introductory curricula for the following areas: (1) the Clery Act; (2) Mission, Vision, and Values of UCPD; and (3) community relations; 2) UCPD sets aside time during the 80-hour orientation training for the new curricula; and 3) We determine whether the new introductory curricula is being taught during the orientation training. UCPD Proffer of Compliance “The University of Cincinnati Police Division has implemented a Training and Professional Development policy that requires an introductory 80-hour orientation training for any newly hired University Law Enforcement Officer that is the precursor to the new officer’s PTO program. The Annual Training Plan, contained within the Training Policy, outlines a total of 93 hours of training for new officers, 80 hours of which are taught in-person or online as the introductory orientation. The specific method of delivery is listed by topic in the table below. Note that some training is always conducted in person, while other training may be conducted online (e-learning format). The UCPD preference, however, is for all training to occur in person when instructor availability permits. Topic Method of Delivery Verbal Defense & Influence

If taught by outside vendor, could be in-person or online If taught in-house, will always be in person

Firearms Always in person Defensive Tactics Always in person


ARMS Always in person Driving Always in person Fair and Impartial Policing

Always in person

Report Writing Could be either Clery Could be either LGBTQ Could be either CPR Always in person Active Threat Always in person ICS Dashboard Always in person Radiation Safety Could be either Title IX Could be either Cultural Diversity Could be either; online if completed through OPOTA, but other

similar courses available in person The most recent hire for the position of University Law Enforcement Officer began the week of October 29, 2017 and completed 80 hours of training between then and November 11, 2017. The curriculum was as follows (see attached documentation):8 hours – Verbal Defense and Influence 8 hours – Firearms 8 hours – Defensive Tactics 8 hours – Driving 8 hours – Fair and Impartial Policing 8 hours – Taser 6 hours – Report Writing 6 hours – Power DMS and Policy Review 4 hours – ARMS 4 hours – Human Resources Orientation 2 hours – Police Training Officer Review 2 hours – Use of Force Policy Review (Proof of UOF Policy Test in Power DMS) 2 hours – Clery Act 1 hours – LGBTQ 1 hour – Union Briefing 1 hour – Victim Services 1 hour – Welcome and Mission, Vision, and Value Review 1 hour – Radio Training from Dispatch In the training of this employee, all training courses were delivered in person. The hours are different than those noted in the Annual Training Plan due to training being conducted one-on-one instead of in a group setting. Further, please note that this list does not exactly match the list in the Annual Training Plan because some of the topics covered were not in existence or use by the UCPD at the time of the ATP’s development (e.g. Taser; Mission, Vision, Values; PTO program). The Training Plan is a living document and is expected to undergo revisions to reflect these new additions in the next 3 months.


As listed above, the introductory curricula includes training regarding the Clery Act as well as the Mission, Vision, and Values of UCPD. Although a specific course on Community Relations is not included, both the Verbal Defense and Influence curriculum and the Fair and Impartial Policing curriculum emphasize appropriate treatment of people and are infused with the importance of establishing positive relationships with the community. Explicit examples from the VDI curriculum can be found on the following pages: Day 1 Power Point : universal greeting (slide 8), tactical peace phrases (slide 60), treatment of others (slides 73 & 74), communicating under pressure (slides 79-81);

Day 2 Power Point: needs assessment activity considering both police and citizen points of view (slide 4), active listening and art of paraphrasing (slides 20-24), redirection, responding to verbal abuse, and deflection, (slides 51, 65-72) debriefing (slides 129-130).

Explicit examples from the FIP curriculum can be found on the following pages: Module 2 as a whole (pages 1-19) discusses the impact of biased policing on community members. Module 3 discusses slowing down interactions with citizens and the importance of engaging with the community as well as examples of how officers can do that (pages 15-18).

Data Reviewed 1. Training and Professional Development Policy 2. Annual Training Plan 3. Orientation Training Roster 4. Verbal Defense and Influence Power Point Presentations Days 1 & 2 5. Fair and Impartial Policing Curriculum Current Assessment of Compliance

In Compliance

As described in the UCPD’s proffer of compliance (above in italics) the 80-hour orientation curriculum for newly hired officers has been supplemented with information on the Clery Act and the UCPD’s Mission, Vision, Values as required by this ER. The UCPD has indicated which courses are required to be conducted in-person versus those that may be conducted online when practical. With regard to Community relations, the Monitor agrees that elements of the topic are covered within the Fair and Impartial Policing, and the Verbal Defense and Influence training. However, given the concentrated community environment as is the case in university campus settings, the Monitor suggests that going forward at least a small portion of the 80 hours is dedicated specifically to community relations as the department seeks to build, enhance and expand the UCPD’s relationships with the diverse local communities and student population. Next Review The Monitor will again assess the UCPD’s compliance with this ER in Q9 (Q1 2019).



DATE: MARCH 13, 2018 REC. REF. NO.: 6.7.B SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding While the hours of mandatory in-service training required of all UCPD employees (16 hours beyond the 2015 State mandated training and 9 hours beyond the new 2016 requirement) is sufficient, additional training time would be beneficial. Exiger Recommendation (“ER”) The curriculum developed should be infused with elements of community policing, including a clear and unified message as to the UCPD’s commitment to community policing, as well as with critical thinking and problem solving skills training throughout. MADC Definition of Compliance Compliance with this recommendation will occur when the UCPD develops a policy requiring inclusion of principles into training and when curriculum is infused with elements of the stated principles. UCPD Proffer of Compliance “The Training and Professional Development (TPD) policy begins with a purpose statement that includes the following statement:

“Policing requires a unique set of problem-solving and critical thinking skills. Problem Oriented Policing (POP) is the UCPD’s primary strategy for crime prevention and organizational improvement. This strategy aligns department policies and procedures with UCPD’s core guiding principles, including, but not limited to, developing and attending innovative training and building positive community partnerships.”

In the Q1 assessment of this Exiger Recommendation, the monitor provided feedback that the UCPD had not fully infused community policing but was reliant on Problem Solving. As described in detail below, the Chief of the UCPD conceptualizes community policing as falling under the umbrella of problem-oriented policing. Community Oriented Policing (COP) and Problem Oriented Policing (POP), although sometimes described as theoretically distinct policing strategies, are regularly used in tandem with each other to address problems. There is disagreement (in both practice and literature) concerning whether POP falls under the umbrella of COP or whether COP is an element of POP. UCPD's objective is to build community relations, promote critical thinking, AND solve problems; therefore,


Problem Oriented Policing will serve as the Department's overarching strategy for the following reasons: (1) POP requires police to regularly engage in COP, but COP does not require police to engage in POP, (2) POP explicitly stresses the importance of critical thinking, and (3) there is little to no evidence that COP can solve crime problems, while research shows that POP is a highly effective crime reduction strategy.

1. POP requires police to regularly engage in COP, but COP does not require police to engage in POP. While COP focuses on relationship building between police and the individuals/organizations they serve, POP is a strategy that allows police to effectively respond to crime and disorder problems. To reduce crime, POP responses often require extensive community outreach and, through implementation, POP efforts effectively build positive and meaningful police-community relationships. As explained by Michael Scott (Director of the Center for Problem-Oriented Policing) and Herman Goldstein (the architect of Problem-Oriented Policing), "Problem-oriented policing depends heavily on strong, mutually trusting partnerships among police and other entities and constituencies," to identify problems, bring stakeholders to the table, and, "adopt responses to community problems that are more equitable and effective," in the communities that they serve (2005, p. 5). Police-community relationship building (the focus of COP) is a function of POP, but COP does not require that police engage in systematic problem-solving (the focus of POP). Scott, M. S., & Goldstein, H. (2005). Shifting and Sharing Responsibility for Public Safety Problems. Problem-Oriented Guides for Police Response Guide Series (No. 3). Washington, DC: U.S. Dept. of Justice, Community Oriented Policing Services. 2. POP explicitly stresses the importance of critical thinking.

The COPS office, in conjunction with the Police Foundation, describe the role of critical thinking as, "...one of the most important skills in conducting problem analysis. Critical thinking is not knowledge about a problem but is a skill of examining and thinking about a problem. It begins with questioning what others believe to be fact and realizing that there is more than one way of examining a problem," (Boba, 2003, p. 25). Problem analysis represents the second step of the SARA model, a commonly used problem-solving method used to develop and execute POP interventions.

Boba, R. (2003). Problem Analysis in Policing. Washington, DC: U.S. Dept. of Justice, Community Oriented Policing Services, Police Foundation.

3. There is little to no evidence that COP can solve crime problems, while research shows that POP is a highly effective crime reduction strategy.


Research fails to find that COP, by itself, can be used reliably to achieve crime reduction. Recent systematic research reviews show that community-oriented policing (COP) strategies have the potential to increase citizen satisfaction with police, as well as positively affect citizen perceptions of disorder and police legitimacy; however, COP strategies have limited effects on crime and fear of crime (e.g., Gill et al. 2014). Alternatively, systematic research reviews have shown that problem-oriented policing (POP) strategies are overwhelming effective in reducing crime and disorder (e.g., Weisburd et al., 2010). POP requires police to do what is best for the community, and this includes, but extends beyond, enhancing police-community relations. Adopting POP rather than COP as UCPD's primary strategy for crime prevention and organizational improvement is aligned with an evidence-based approach to developing effective police policy and practice.

Gill, C., Weisburd, D., Telep, C. W., Vitter, Z., & Bennett, T. (2014). Community-Oriented Policing to Reduce Crime, Disorder and Fear and Increase Satisfaction and Legitimacy among Citizens: A Systematic Review. Journal of Experimental Criminology, 10(4): 399–428. Weisburd, D., Telep, C. W., Hinkle, J. C. & Eck, J. E. (2010). Is Problem-Oriented Policing Effective in Reducing Crime and Disorder?. Criminology & Public Policy, 9(1): 139–172.

Furthermore, it is the Chief’s preference to leave training-specific information as the focus of the TPD Policy; information regarding the division’s approach to problem solving (as summarized above) more appropriately belongs in a stand-alone policy, to which the TPD policy will refer once completed. This new policy is expected to be completed and ready for assessment in Q7. The TPD Policy includes the following on the list of competencies for all patrol officers (pages 5-6), all of which are related to critical thinking, problem solving and/or community policing:

Conflict resolution Problem Solving Community-Specific Problems Cultural Diversity and Special Needs Groups Communication Team Work

All training (see attached UCPD Training Plan) is evaluated for its support of these competencies as well as for consistency with the UCPD Vision, Mission Statement, and Core Principles (provided to the monitor in Quarter 2 for ER 1.1.A/5.2.A), the latter of which explicitly references transparency, partnering with the community, and collaborative problem solving through community involvement. Therefore, even training courses that are not specifically labeled as community policing, problem solving, or community relations/engagement routinely incorporate skills and tactics for critical thinking, problem solving, appropriate customer service, de-escalation, and respectful interactions with the community. See for example the curriculums of the following training: Fair and Impartial Policing, Verbal Defense and Influence, and Crisis Intervention Team. These skills are emphasized for and expected of all employees. In addition, the PTO program for new hires is a problem-based learning model based on


community policing and collaborative problem solving principles (p.4 TPD Policy), the Community Advisory Council has a sitting member on the Training Committee (p.4 TPD Policy) and trends in campus community crime and disorder is listed as one of the topic for consideration in the annual Training Needs Analysis (p.10 TPD Policy). 2018 training focused on these principles (labeled Problem Solving Refresher 4 hrs on the attached Annual Training Plan) has not yet been determined, but will likely occur in the fall. Recognizing the importance of a quality relationship between all UCPD personnel and the UC community, this training is required of all UCPD employees (e.g., supervisors, law enforcement officers, security officers, and dispatchers). The monitor will be advised as to the contents of this training and its scheduled date once it is available.” Data Reviewed UCPD Training and Development Policy dated March 22, 2017 Prior Assessment of Compliance The Monitor last assessed the UCPD’s compliance with this ER in Q1, ending March 31, 2017. At that time the Monitor found the UCPD in compliance but suggested that UCPD’s policy place a stronger emphasis on the concept that all UCPD officers are responsible for on-going community policing, as opposed to referring only to the problem solving function which is sometimes seen as a singular task-oriented type of activity – i.e., once a particular problem is solved, community policing is done. Regardless of the terminology used, the Monitor recognized that the UCPD was in fact “infusing” its training with elements of community policing such as problem solving skills and critical thinking.


In Compliance

As described in the UCPD’s proffer of compliance (above in italics), the UCPD has continued to include community policing as a guiding principle for its training program and has included problem solving and critical thinking within the courses it chooses for its officers to attend as these are important tools to further build positive community relations. It is the Monitor’s belief that the UCPD command staff truly strives for a quality relationship between all officers and the UC campus community. Next Review No further review of this ER is necessary.


COMPLIANCE MEMORANDUM DATE: MARCH 31, 2018 REC. REF. NO.: 6.7.G SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding While the hours of mandatory in-service training required of all UCPD employees (16 hours beyond the 2015 State mandated training and 9 hours beyond the new 2016 requirement) is sufficient, additional training time would be beneficial. Exiger Recommendation (“ER”) Increase diversity and biased policing training and require these subjects to be recurrent training annually. MADC Definition of Compliance Compliance with this recommendation will occur when UCPD implements a policy requiring that diversity training and biased policing training occur annually. Proffer of Compliance from UCPD “The University of Cincinnati Police Division implemented a policy regarding bias-free policing in May 2016 that explicitly states that officers may not use race, color, ethnicity, or national origin, to any extent or degree (see page 2 of attached Bias-Free Policing policy). The most recent version of this policy was published and fully disseminated to UCPD personnel in December 2017. Evidence of such is available to the monitor via PowerDMS. This policy requires annual refresher training on bias-free policing on page 4 as well as initial bias-free policing training to new officers. As required by the Bias-Free Policing Policy and the Training and Professional Development policy (also attached), every new officer hired by UCPD has been trained in Fair and Impartial policing. This 8-hour training course is included in the 80 hours of training required of new hires before going out with a training officer. One of the two certified Fair and Impartial Policing (FIP) trainers provided the 8 hours of this training for newly hired officers in 2017. Their instructor training certificates, Fair and Impartial Policing Lesson Plans and Curriculum, and FIP Scenario Training and Case Study Guidebook were all previously submitted in Q1. The training documentation for these new officers is attached. In 2017, the annual refresher training (4 hours) on this topic was covered by the OPOTA-mandated training for Procedural Justice and Police Legitimacy. This training was mandatory for every Ohio officer to keep their commission; attached are the sign-in sheets and lesson plans regarding what the state required.


In February 2018, 19 of 22 security officers were trained in Fair and Impartial Policing as mandated by the UCPD Training Plan. Their training sign-in rosters are attached. The remaining security officers were unable to complete the training at this time due to lack of coverage at a branch campus (2 SOs) and being on leave during the training (1 SO). At this time, an annual refresher training is only required for law enforcement officers. Additionally, beginning in January 2018, all dispatchers will attend multiple classes hosted by the University of Cincinnati Office of Equity and Inclusion (OEI) as these classes are much more relevant to their position; the FIP course is much more applicable to those specifically involved with law enforcement. In 2018, the refresher training will be covered by the OEI.” Data Reviewed 1. Bias Free Policing Policy 4.1.300 2. Training Policy 6.1.100 3. Fair and Impartial Policing New Hire Roster 4. Fair and Impartial Policing Security Roster (forthcoming in late February) 5. OPOTA Power Point with Lesson Plan in note section 6. OPOTA Rosters Prior Assessment of Compliance The Monitor first assessed the UCPD’s compliance with ER 6.7.G in Q1 ending March 31, 2017, finding the UCPD in compliance as quality diversity and bias policing training had increased and had been delivered to all UCPD employees in 2016. Current Assessment of Compliance In Compliance As described in the UCPD’s proffer of compliance (above in italics), the UCPD ensures that both new sworn officers and in-service officers receive diversity and bias policing as required by this ER. The documentation submitted in connection with the 2017 4-hour annual refresher training on this topic was covered by the OPOTA-mandated training for Procedural Justice and Police Legitimacy. While this training was mandatory for every Ohio commissioned officer and clearly covered important topics such as the “Peelian” principles; positive versus negative community contacts; trustworthiness; and, treating people with respect - the course did not truly speak to issues surrounding biases or diversity. The word diversity was not used and the word bias was used once within the presentation in relation to being neutral, transparent, consistent in enforcement, loyal only to the law, and “free from bias.” The Monitor suggests that the refresher training for 2018 be more carefully evaluated to ensure it clearly and specifically covers diversity and biased policing. Next Review The Monitor will again assess the UCPD’s compliance with this ER in Q9 (Q1 2019).

Office of the Independent Monitor

University of Cincinnati Police Department


DATE: APRIL 15, 2018

REC. REF. NO.: 6.12.C

SUBJECT: ASSESSMENT OF COMPLIANCE

Exiger Finding

Training delivery currently is left to the discretion of each individual instructor at UCPD. There is

no standard requirement that the training include role play, scenarios or table top exercises and no

indication that adult learning methodology is consistently applied.

Exiger Recommendation (“ER”)

Develop problem-based scenarios and case studies that allow the student to apply problem solving

skills and knowledge of diverse populations.

MADC Definition of Compliance

Compliance with this recommendation will occur when:

1) UCPD implements a policy requiring that training include problem-based scenarios and case

studies that allow the student to apply problem solving skills and knowledge of diverse

populations; and

2) UCPD training courses include problem-based scenarios and case studies that allow the student

to apply problem solving skills and knowledge of diverse populations.

Note: The above requirements are meant to apply to any training taught/delivered by UCPD

instructors with the exception of OPOTA mandated curriculum.

UCPD Proffer of Compliance

“The University of Cincinnati Police Division has developed a Training and Professional

Development policy, which incorporates several Exiger recommendations. The policy component

of compliance with 6.12.C begins on page 11 under the “Approval” section. The policy

specifically lists the “inclusion of problem-based scenarios” as one of the minimum requirements

that must be met before a course will be added to the UCPD curriculum.

In order to ensure vendor-developed training includes problem-based scenarios as required, the

course review/approval forms used by the Training Section specifically include reference to this:

• Course Consideration Analysis Form 100A (used for vendor developed training that may

be delivered by vendor or by in-house certified instructor; completed in advance of

attendance at the training):

o delivery method (whether PowerPoint, scenario-based, practical application),

o review of participant guide and facilitator guide when available,

o whether course includes practical application,

o whether course includes problem solving, and



o how course supports the UCPD vision statement, mission statement, and core

principles/values.

• Vendor Course Review Form 100B (used for vendor developed training that may be

delivered by vendor or by in-house certified instructor; completed during attendance at

the training)

o Delivery Method

o Provides participants adequate time to practice the new skill

o Incorporates reality based scenarios and/or case studies

As required on page 13 of the TPD policy, “All internally developed courses will adhere to the

minimum approval requirements,” which as stated above include problem-based scenarios.

Although the UCPD has not yet developed internal training courses, the Internal Course Review

Form 100C and New Course Approval Form 100D ensure problem-based scenarios are included

in internally developed and delivered training).

• Internal Course Review Form 100C includes:

o Whether tell/show/do format is incorporated

o Whether course allows for critical thinking

o Whether course incorporates problem solving opportunities

o Whether activities include real-world examples of how the learning can be

applied?

• New Course Approval Form 100D includes:

o Space to fill in related Competencies fulfilled by this course (problem solving is

among the competencies listed in the TPD policy),

o Delivery method,

o And an affirmative statement that “The course listed above has been fully vetted

and is consistent with UCPD policies and procedures as well as the agency

mission, vision, and values,” with appropriate supporting vetting documentation

attached.

Furthermore, as required by policy on page 15, “the Training Unit Lieutenant or designee will

use the Trainer Observation and Evaluation (Form 100I) to formally evaluate all UCPD and

Vendor trainers against six training competencies: preparedness, creating a comfortable

learning environment, classroom management control, communication, facilitation, and content

knowledge. Two of these are specifically related to ensuring the use of problem-based scenarios:

• Facilitation: Allowed time for learners to practice their new skill/knowledge; Reviewed

instructions for all activities; Debriefed all activities and tied the learning to the

objectives

• Content Knowledge: Presented content accurately; Followed the outline in the

Facilitator Guide

The only 2017 Training course that was UCPD-delivered and non-OPOTA mandated was Taser.

The training for this weapon is required by the manufacturer and their curriculum must be used.

The instructor booklet, PowerPoint, scenarios, syllabus and attendance rosters for the Taser

course were previously submitted to the monitor in Q4 in conjunction with ERs 1.7.C and 10.1.C.

In the decision-making process to use these weapons, however, the Training unit ensured that the



training meets the requirements of the Exiger recommendations and/or supplemented it where

possible. For example, the in-house Taser instructors supplemented with additional scenario-

based training that the monitor team observed. In light of the different sources of training that the

UCPD delivers and attends, the Training Section is in the process of modifying their review and

approval documentation to streamline the process in collaboration with the monitor.

Finally, this review and approval process was completed for the ALERRT and ICAT training

courses in preparation for them to be delivered by in-house UCPD instructors in 2018 (see Forms

100A, B, and D submitted in connection to ER 4.11.A for ALERRT and Forms 100A and D for

ICAT) and was also completed for the FLETC supervisory training in anticipation of sending new

supervisors to that outside vendor training in 2018 (see Forms 100A and D submitted in

connection to ER 6.14.A, 6.15.D). Data Reviewed

1. Training and Development Policy

2. Course Consideration Analysis Form 100A

3. Vendor Course Review Form 100B

4. Internal Course Review Form 100C

5. New Course Approval Form 100D

6. Trainer Observation and Evaluation Form 100I

Prior Assessment of Compliance

During Q1 ending March 31, 2017, the Monitor found the UCPD in compliance with this ER as

the policy required that training include problem-based scenarios and specific case studies that

reinforce knowledge of diverse populations, the responsibility of which was given to the Training

Unit.


In Compliance

During the current period, in order to test implementation of the policy, the Monitor reviewed the

curriculum for the Taser training which clearly includes problem-based scenarios. The Monitor

also happened to attend at least one of these training sessions and observed the delivery which did

in fact allow students to apply problem solving skills and was clearly meant to test the students’

knowledge of dealing with different members of the campus community.

While a review of the above curriculum demonstrated compliance, during its review the Monitor

noted several areas for improvements in the manner that the curriculum is acquired, retained and/or

reviewed. As an example, there currently are at least six different forms for basically documenting

similar steps in the evaluation and review of training, but the specific form to be used depends on

the circumstance surrounding the training causing the process to be onerous and unwieldy. In

summary, the Monitor and the UCPD agreed to address the above and other issues in a

collaborative manner in the coming weeks, but at a minimum, going forward, documentation

similar to the Taser training curriculum should be provided on all courses taught by UCPD

instructors regardless of how many officers attended, or whether or not it is meant to be added to



the training scheduled. Further, the UCPD must develop a comprehensive list to include all

training attended by UCPD personnel.

Next Review

The Monitor will again assess the UCPD’s compliance with ER 6.12.C in Q9 (Q1 2019.)


COMPLIANCE MEMORANDUM DATE: APRIL 16, 2018 REC. REF. NO.: 6.12.D SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding Training delivery currently is left to the discretion of each individual instructor at UCPD. There is no standard requirement that the training include role play, scenarios or table top exercises and no indication that adult learning methodology is consistently applied. Exiger Recommendation (“ER”) Require curriculum review before a class is taught. MADC Definition of Compliance Compliance with this recommendation will occur when: 1) UCPD implements a policy requiring that curriculum be reviewed before a class is taught;

and 2) UCPD has assigned the task of reviewing curriculum to an individual or group of individuals

who are qualified and knowledgeable about best practices in training and policing in an urban campus environment.

Note: The above requirements are meant to apply to any training taught/delivered by UCPD instructors with the exception of OPOTA mandated curriculum. UCPD Proffer of Compliance “The University of Cincinnati Police Division’s Training and Professional Development Policy (attached) requires that all non-OPOTA mandated training be reviewed and approved by the Training Section Supervisor or his/her designee, prior to the course being taught. Currently, before a course is taught by an in-house instructor, the training is reviewed through the Course Consideration Analysis Form 100A and/or the Vendor Course Review Form 100B; the determination on how to review is made based on whether or not there are similar courses for the purposes of comparison. Attached are examples of a recent course consideration analysis, completed by the Training Consultant for new supervisory training, as well as the course description and syllabus and new course approval form. No additional course consideration analyses have been conducted since the monitor’s Q4 assessment of ER 6.12.D.” Data Reviewed 1. Training Policy 2. Course Consideration Analysis, Course Approvals, and Courses Descriptions for Active

Shooter Training


Prior Assessment of Compliance During Q2 ending June 30, 2017, the Monitor found the UCPD in compliance with this ER as the policy requirements and standards at the time of the review had been met. The Monitor noted that while the Training Review Committee, which was determined to be the mechanism for course evaluation had not yet convened or reviewed any training. During Q4 ending December 31, 2017, the Monitor and UCPD clarified that the responsibility for the review of training curriculum before a class was taught rested with the Training Section (“TS”) Supervisor, the TS Coordinator, the Training Review Committee, and finally, the UCPD Command staff – all of whom combined are qualified and knowledgeable about best practices in training and policing in an urban campus environment. The Monitor noted that the many forms referenced in the policy and used to document this review had been updated for consistency. Current Assessment of Compliance

In Compliance

During the current period, in order to test the documentation associated with implementation of the UCPD’s policy, the Monitor requested a list of all training provided from which it would randomly select training for a more thorough review.1 After reviewing some documentation and having several follow-up discussions it was determined that the best examples of UCPD’s compliance with this ER is the curricula review of the planned Active Shooter Training titled “Advanced Law Enforcement Rapid Response Training” (ALERRT) and “Integrating Communications, Assessment and Tactics” (ICAT). These courses will be taught by UCPD instructors after having attended train-the-trainer course and were clearly evaluated prior to being delivered. While the above documentation demonstrates compliance, during its review the Monitor noted several areas of the UCPD’s policy and processes that are in need of clarification and streamlining. Specifically, the manner in which curriculum is requested, acquired, and retained including the documented review. As an example, even though the Taser training was required in order to deploy Tasers, and the curriculum was created by Taser and delivered by UCPD’s weapons instructors, according to the Training Unit, a review of the curriculum was not conducted prior to the course being taught. As a result of its review this period, the Monitor and the UCPD have agreed to address these and other issues in a collaborative manner in the coming weeks. At a minimum, going forward, documentation similar to the ALERRT and ICAT should be provided on all courses that are taught by UCPD instructors. And the UCPD must develop a comprehensive listing that includes any and

1 After reviewing the UCPD’s submission and after several follow-up discussions, it was decided that this ER was meant to address only those courses and training taught by UCPD instructors because the review of training taught by outside vendors is covered by a ER 6.14.A. As a result the MADC were modified to reflect this point.


all training attended by its members and ensure such information is included in the new Learning Management System going forward. Next Review The Monitor will assess compliance with this ER on an on-going basis to include a review of all training courses taught by UCPD instructors. At a minimum, the next scheduled review will be in Q9 ending March 31, 2019.



DATE: APRIL 10, 2018 REC. REF. NO.: 6.14.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding The majority of continuing education training for all employees is conducted off-site, by non-UCPD instructors and without any requirement that the curricula be reviewed or approved by UCPD or that officers who attend such training bring a copy of the syllabus back for their training files. Exiger Recommendation (“ER”) UCPD should require by policy that all non-UCPD training [outside vendor] be reviewed and approved prior to authorizing attendance at such program, and that a syllabus of such training be obtained for inclusion in the attending employee’s file. MADC Definition of Compliance Compliance with this recommendation will occur when: 1) UCPD implements a policy requiring that all non-UCPD training be reviewed and approved prior to authorizing attendance at such program, and that a syllabus of such training be obtained for inclusion in the attending employee’s file; 2) We obtain proof that the policy is being followed in practice; 3) UCPD has assigned the task of reviewing and approving non-UCPD training to an individual or group of individuals who are qualified and knowledgeable about best practices in training and policing in an urban campus environment. Note: This is not meant to cover OPOTA or other state of Ohio mandated training. UCPD Proffer of Compliance “The University of Cincinnati Police Division’s Training and Professional Development Policy (attached) requires that all non-UCPD training be reviewed and approved prior to authorizing attendance at such program. Currently, all courses are reviewed through the training request and/or through the Course Consideration Analysis; the determination on how to review is made on whether or not there are similar courses for the purposes of comparison. Every training request must also include the course description with its syllabus/curriculum to be taught. Attached are examples of a recent course consideration analysis, course approval, and a course description with syllabus to show the implementation of this recommendation. Additional documents may be requested by the monitor for courses listed in the Training Request Tracker (attached), but no additional course consideration analyses have been conducted since the monitor’s Q4 assessment of ER 6.12.D.” Data Reviewed 1. Training Policy


2. Training request Tracker 3. New Supervisor Course Consideration Analysis 4. New Supervisor Course Approval 5. FLETC Description with syllabus Prior Assessment of Compliance During Q1 ending March 31, 2017, the Monitor found the UCPD in compliance with this ER as the policy requirements and standards at the time of the review had been met. The Monitor noted that the policy outlined the evaluation process for outside vendor taught courses and provided feedback that the documentation needed additional detail to ensure proper tracking. Lastly, a syllabus or copy of the course content must be maintained and associated with the attending employee. Current Assessment of Compliance

Partial Compliance

As stated in the UCPD’s proffer of compliance (above in italics), the UCPD submitted the course consideration analysis, evaluation and approval documentation for the supervisory course (FLETC) as an example of compliance. The Monitor reviewed that documentation and except for not identifying the person who conducted the analysis, the documentation was sufficient for that particular course. To further test implementation, the Monitor requested follow-up documentation from the UCPD’s list of training. Specifically the Monitor randomly selected a few vendor courses that were listed as having been attended – one on sexual assault response and investigation, and one on crowd control, and requested a copy of the syllabus for the course on the Glock firearms to ensure it was retained as an accurate record of employee training as required. The Training Unit forwarded the Glock syllabus which demonstrated compliance with keeping training records attached to employee files, but was not able to provide similar evaluation documentation (“course consideration analysis and evaluation”) for those two courses. Rather, the UCPD submitted the associated training request forms which do indicate supervisory approval but does not adequately document an assessment. The Training Unit staff indicated that the sexual assault investigation course was only offered one time by CPD and the UC Title IX office which prevented a full evaluation prior to attendance, and the crowd control course was not evaluated because the Chief said the course had to be done immediately as it related to a specific time sensitive events and was critical to have officers attend the training expeditiously. While the above documentation demonstrates partial compliance, during its review the Monitor noted several areas of the UCPD’s policy and processes that are in need of clarification and streamlining. Specifically, the manner in which curriculum is requested, acquired, and retained including the documented review. As a result, the Monitor and the UCPD have agreed to address these and other issues in a collaborative manner in the coming weeks. Next Review The Monitor will assess the UCPD’s compliance with this ER in Q7 ending September 30, 2018.


COMPLIANCE MEMORANDUM DATE: APRIL 16, 2018 REC. REF. NO.: 6.15.D SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding There are serious deficiencies noted in command oversight of training including: the lack of a Training Committee (despite it being named in the SOP); the lack of review (or available evidence of review) of course curricula by the TU Lieutenant or Training Committee; the lack of an annual Continuing Education Plan and Learning Needs Assessment; and the lack of oversight over outside training. Exiger Recommendation (“ER”) UCPD should review, approve, and maintain the curriculum of every outside course approved for attendance by a UCPD officer. MADC Definition of Compliance Compliance with this recommendation will occur when UCPD implements a policy requiring that it review, approve, and maintain the curriculum of every outside course approved for attendance by a UCPD officer; and, is in practice, reviewing, approving, and maintaining the curriculum of every outside course approved for attendance by a UCPD officer. UCPD Proffer of Compliance “The University of Cincinnati Police Division’s Training and Professional Development Policy (attached) requires that all non-UCPD training be reviewed and approved prior to authorizing attendance at such program. Currently, all courses are reviewed through the training request and/or through the Course Consideration Analysis; the determination on how to review is made on whether or not there are similar courses for the purposes of comparison. Every training request must also include the course description with its syllabus/curriculum to be taught. Attached are examples of a recent course consideration analysis, course approval, and a course description with syllabus to show the implementation of this recommendation. Additional documents may be requested by the monitor for courses listed in the Training Request Tracker (attached), but no additional course consideration analyses have been conducted since the monitor’s Q4 assessment of ER 6.12.D.” Data Reviewed 1. Training Policy 2. Training request Tracker 3. New Supervisor Course Consideration Analysis 4. New Supervisor Course Approval 5. FLETC Description with syllabus


Prior Assessment of Compliance During Q1 ending March 31, 2017, the Monitor found the UCPD in compliance with this ER as the policy outlined the process to be followed to review, approve and retain training curricula as required. The UCPD submitted examples course curricula as a means of demonstrating their requirement to retain such materials. Current Assessment of Compliance

Partial Compliance

As stated in the UCPD’s proffer of compliance (above in italics), the UCPD submitted the outside training course syllabus for the supervisory course (FLETC) as an example of compliance. To further test implementation, the Monitor requested follow-up documentation from the UCPD’s list of training, specifically curriculum for the outside vendor courses listed as having been attended by UCPD employees, one on sexual assault response and investigation and one on crowd control. While the Training Unit provided a flyer that contained an outline of the sexual assault course, it was not able to provide similar the curriculum for the crowd control course stating that often they do not was not evaluated because the Chief said the course had to be done immediately as it related to a specific time sensitive issue. While the above documentation demonstrates partial compliance, during its review the Monitor noted several areas of the UCPD’s policy and processes that are in need of clarification and streamlining. Specifically, the manner in which curriculum is requested, acquired, and retained including the documented review. As a result, the Monitor and the UCPD have agreed to address these and other issues in a collaborative manner in the coming weeks. Next Review The Monitor will again assess the UCPD’s compliance with this recommendation in Q7 ending September 30, 2018.


COMPLIANCE MEMORANDUM DATE: APRIL 16, 2018 REC. REF. NO.: 6.16.C SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding The Training Unit lacks basic management practices including: the lack of creation, maintenance and retention of curriculum, expanded course outlines, and/or lesson plans for courses; best practice templates for the design and evaluation of training; and regular course assessments. Exiger Recommendation (“ER”) UCPD should complete regular assessments of courses and training delivery and ensure that curricula include relevant and realistic officer tasks and competencies. MADC Definition of Compliance Compliance with this recommendation will occur when: 1) UCPD implements policies and procedures requiring regular assessments of courses and training; 2) The policy assures that the assessments are conducted in such a way to ensure that a curriculum includes relevant and realistic officer tasks and competencies; 3) These assessments are, in practice, being performed in such a way to ensure that curricula includes relevant and realistic officer tasks and competencies (on-going) 4) The individuals assigned to conduct these assessments are qualified and knowledgeable about best practices in training and policing in an urban campus environment (on-going) UCPD Proffer of Compliance “The University of Cincinnati Police Division has created a Training and Professional Development Policy (attached) that requires all internal and external courses, as well as instructors, to be evaluated. Instructors are evaluated by the students when completing a course, as well as evaluated by the Training Section Supervisor or his/her designee on an annual basis (see attached Forms 100H and 100I). In the past, evaluations have been completed on paper, but the new Learning Management System (LMS) has the ability to ensure reviews are completed anonymously by the officer and that the class will not show as completed until the review is completed. Attached the monitor will find the 2017 Training Request Tracker and the 2017 Continuing Professional Development spreadsheet, listing trainings attended and from which the monitor may request additional documentation to show the UCPD’s compliance with the implementation of the evaluation processes. The completion of these evaluation forms on an ongoing basis provides one of the many sources of information included for review and consideration during the annual Training Needs Analysis (see page 14 of the TPD policy). As described on pages 9 and 10 of the TPD policy, “In an effort to maintain a curriculum that continually aligns with UCPD’s mission, vision, and values, and


includes relevant and realistic employee tasks, the Training Committee will conduct an annual Training Needs Analysis (TNA). The results of this analysis will determine whether courses are to be continued, updated, or retired.” The 2018 annual Training Needs Analysis is not scheduled until June 2018, so further documentation of this process is not expected to be available to the monitor until late in Q6 or Q7. Furthermore, due to the large number of new trainings that have been implemented in the last two years, there has not been a recent annual review of an ongoing course. Data Reviewed 1. Training Policy 2. 2017 CPT spreadsheet 3. 2017 Training Request Tracker 4. Trainer Observation and Evaluation (Form 100I) 5. Student Course and Trainer Evaluation (Form 100H) Prior Assessment of Compliance During Q1 ending March 31, 2017, the Monitor found the UCPD in compliance with this ER as the policy outlined the process to be followed to complete regular assessments of courses and training delivery and ensure that curricula include relevant and realistic officer tasks and competencies as required. The UCPD submitted an Annual Training Schedule as part of the Training policy which included the task and competencies for officers, sergeants, security officers and dispatchers and explained that the established Training Review Committee appointed by the Chief of Police includes the key members of the Department including the Training Unit staff, other members of the UCPD (an officer, a sergeant, a union representative, and a dispatch officer) and outside elements to include a member of the Student Safety Board and the Community Advisory Council. Current Assessment of Compliance DW - Determination Withheld As stated in the UCPD’s proffer of compliance (above in italics), the UCPD specifically requires training courses be evaluated on an ongoing basis and has completed some documentation in that regard. However, the Training Needs Analysis (TNA) which is purported to be conducted by the Training Review Committee which is an integral part of the process as articulated by UCPD in its policy and its Q1 proffer of compliance, has not yet been completed. The TNA is currently scheduled to be complete in June 2018. Consequently the Monitor is withholding its determination of compliance until documented evidence of compliance is submitted. Next Review The Monitor will again assess the UCPD’s compliance with this recommendation in Q7 ending September 30, 2018.



DATE: APRIL 10, 2018 REC. REF. NO.: 6.16.D SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding The Training Unit lacks basic management practices including: the lack of creation, maintenance and retention of curriculum, expanded course outlines, and/or lesson plans for courses; best practice templates for the design and evaluation of training; and regular course assessments. Exiger Recommendation (“ER”) Ensure that the TU Lieutenant approve all internal courses and lesson plans, and approve all outside courses prior to employees being allowed to attend to ensure consistency with UCPD policies, procedures, practices and agency mission, vision, and values. MADC Definition of Compliance Compliance with this recommendation will occur when: 1) UCPD implements a policy requiring that the TU Lieutenant approve all internal courses and lesson plans; 2) UCPD implements a policy requiring that the TU Lieutenant approve all outside courses prior to employees being allowed to attend; 3) The TU Lieutenant is, in fact, approving all internal courses and lesson plans, and approving all outside courses prior to employees being allowed to attend; and 4) When approving courses, the TU Lieutenant is ensuring consistency with UCPD policies, procedures, practices and agency mission, vision, and values. UCPD Proffer of Compliance “The University of Cincinnati Police Division has created a Training and Professional Development Policy (attached) that requires all courses, internal and external, to be reviewed and approved by the Training Lieutenant or an assigned delegate prior to attendance. The training policy requires the mandatory attendance by the training Lieutenant or an appropriate delegate for the purpose of evaluation. This evaluation will help to ensure that any training implemented is effective along with being in alignment with the UCPD mission and values. Prior to attendance at a course, a Course Consideration Analysis is completed. Once the course is attended the evaluation is completed by a designated delegate. This allows for future consideration of the course and whether UCPD will continue with specific courses. The training policy also specifically requires training courses and instructors to be evaluated. Evaluation, assessment, and implementation are completed on an ongoing basis. Instructors are evaluated by the students when completing a course, as well as evaluated by the Training Lieutenant or an appropriate delegate on a yearly basis. In the past, reviews have been completed on paper, but the new Learning Management System (LMS) has the ability to ensure reviews are


completed anonymously by the officer and that the class will not show as completed until the review is completed. Template documents for these processes are listed below. Some were previously provided to the monitor for these specific recommendations in Q1, while others were previously submitted in support of other training-related recommendations. Attached the monitor will find the 2017 Training Request Tracker, from which the monitor may request additional documentation to show the UCPD’s compliance with the implementation part of the review, approval, and evaluation processes.”

Form 100A Course Consideration Analysis Form 100B Vendor Course Review Form 100C Internal Course Review Form 100D New Course Approval Form 100E Public Safety Training Request Form 100H Student Course and Trainer Evaluation Form 100I Trainer Observation and Evaluation

Data Reviewed 1. UCPD Training and Development Policy dated March 22, 2017 2. UCPD Training Course Approval Draft

Prior Assessment of Compliance The Monitor last assessed the UCPD’s compliance with this requirement in Q1 ending March 31, 2017 and found that the UCPD met the policy requirements but needed to conduct a more in-depth evaluation of the implementation of the procedures during its next review as such procedures had not yet been fully implemented.

Current Assessment of Compliance In Compliance During the current period, in order to test the documentation associated with implementation of the UCPD’s policy, the Monitor requested a list of all training provided from which it would randomly select training for a more thorough review. After reviewing the documentation submitted and having several follow-up discussions it was determined that for the most part, the documentation demonstrates that the TU Lieutenant is in fact approving training to ensure consistency with UCPD policies, procedures, practices and agency mission, vision, and values. While a review of the above curriculum demonstrated compliance the manner in which the approval of training courses and lesson plans is documented is inconsistent and differs depending on too many variables making the process of documentation retention onerous and unwieldy. As stated elsewhere in this report, the Monitor’s review noted several areas of the UCPD’s policy and processes that are in need of clarification and streamlining. The Monitor and the UCPD have agreed to address these and other issues in a collaborative manner in the coming weeks.


Next Review The Monitor will again assess the UCPD’s compliance with this recommendation in Q9 ending March 31, 2019.


COMPLIANCE MEMORANDUM DATE: MARCH 29, 2018 REC. REF. NO.: 6.19.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding There is no policy that requires the TU Lieutenant to attend training for the purpose of oversight of the training being presented. Exiger Recommendation (“ER”) Ensure that UCPD develops a policy which charges the TU Lieutenant or appropriate designee with mandatory attendance of training in order to evaluate, in writing, its effectiveness. MADC Definition of Compliance Compliance with this recommendation will occur when: 1) UCPD implements a policy which charges the TU Lieutenant with mandatory attendance of training in order to evaluate, in writing, its effectiveness; 2) The policy is in line with best practices in the industry; and 3) The policy is being followed in practice. Note: This recommendation is not meant to require that UCPD evaluate any OPOTA training. UCPD Proffer of Compliance “The University of Cincinnati Police Division has created a Training and Professional Development Policy (attached) that requires all courses, internal and external, to be reviewed and approved by the Training Lieutenant or an assigned delegate prior to attendance. The training policy requires the mandatory attendance by the training Lieutenant or an appropriate delegate for the purpose of evaluation. This evaluation will help to ensure that any training implemented is effective along with being in alignment with the UCPD mission and values. Prior to attendance at a course, a Course Consideration Analysis is completed. Once the course is attended the evaluation is completed by a designated delegate. This allows for future consideration of the course and whether UCPD will continue with specific courses. The training policy also specifically requires training courses and instructors to be evaluated. Evaluation, assessment, and implementation are completed on an ongoing basis. Instructors are evaluated by the students when completing a course, as well as evaluated by the Training Lieutenant or an appropriate delegate on a yearly basis. In the past, reviews have been completed on paper, but the new Learning Management System (LMS) has the ability to ensure reviews are completed anonymously by the officer and that the class will not show as completed until the review is completed.


Template documents for these processes are listed below. Some were previously provided to the monitor for these specific recommendations in Q1, while others were previously submitted in support of other training-related recommendations. Attached the monitor will find the 2017 Training Request Tracker, from which the monitor may request additional documentation to show the UCPD’s compliance with the implementation part of the review, approval, and evaluation processes.

Form 100A Course Consideration Analysis Form 100B Vendor Course Review Form 100C Internal Course Review Form 100D New Course Approval Form 100E Public Safety Training Request Form 100H Student Course and Trainer Evaluation Form 100I Trainer Observation and Evaluation

Data Reviewed 1. UCPD Training and Development Policy dated March 22, 2017 2. Training Request Tracker

Prior Assessment The Monitor last assessed the UCPD’s compliance with this ER in Q1 ending March 31, 2017, finding the UCPD in compliance as its Training policy adequately outlined the duties and responsibilities of the Training Unit lieutenant or designee to personally observe and evaluate every UCPD and outside/Vendor.


Partial Compliance

While the UCPD’s proffer of compliance (above in italics), states that the policy requires the mandatory attendance by the training Lieutenant or an appropriate delegate for the purpose of evaluation, currently the documentation does not adequately demonstrate that this process has been fully implemented. Based on follow-up conversations with UCPD staff, it appears that some exceptions based on the unnecessary step of attending obvious reliable courses such as those designed by reputable Federal and/or State agencies and other exceptions exists wherein logistical constraints need to be factored into the process. As stated elsewhere in this report, the Monitor’s review noted several areas of the UCPD’s policy and processes that are in need of clarification and streamlining. The Monitor and the UCPD have agreed to address these and other issues in a collaborative manner in the coming weeks. Next Review The Monitor will again assess the UCPD’s compliance with this ER in Q7, ending September 30, 2018.


COMPLIANCE MEMORANDUM DATE: FEBRUARY 20, 2018 REC. REF. NO.: 6.22.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding The UCPD currently has a basic OPOTC-certified Police Academy located on its Clermont campus which is unused by UCPD. Exiger Recommendation (“ER”) UCPD should consider utilizing the Clermont Campus OPOTC-certified Police Academy as its own internal academy where UCPD sponsored/hired cadets could attend. MADC Definition of Compliance Compliance with this recommendation will occur when UCPD proves that it gave meaningful consideration to utilizing the Clermont Campus OPOTC-certified Police Academy as its own internal academy where UCPD sponsored/hired cadets could attend. UCPD Proffer of Compliance “UC Public Safety Department leadership thoroughly investigated and considered the possibility of utilizing the Clermont Campus OPOTA-certified police academy where sponsored cadets could attend. After careful consideration, it was determined that the best police training available in this region is available at the Cincinnati Police Academy. Arrangements have been made for UC police new-hires to attend CPD’s Academy for basic certification training. In fact, UCPD has two recruits currently attending CPD’s Academy. Additionally, CPD has made substantial initial investment in creating a regional police academy for all agencies in this region. From a quality training perspective as well as a reasonable and efficient business decision, UC will utilize CPD’s Academy for police new hires.” Data Reviewed No additional materials were reviewed. Current Assessment of Compliance

In Compliance

As described in the UCPD’s proffer of compliance (above in italics) the UCPD has decided to use the Cincinnati Police Department’s police academy, which is also certified by the Ohio Peace Officer Training Commission (OPOTC), to train all of its newly hired police recruits. The Monitor applauds the decision as it will ensure that its new officers receive quality training consistent with other agencies in the region.


Next Review No further review of this ER is needed.

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec

7.1.A Each of the three patrol shifts should be made up of two squads of officers, with each squad having a permanently assigned sergeant who works the same rotating schedules as their officers. - - - - - - - - - - -

7.1.BConsider redesigning the Organization chart so that it is comprised of sub charts showing Field Operations and Support Services in greater detail, and should be updated to reflect latest changes and clearly reflect each squad sergeant and the officers assigned to the squad.

- - - - - - - - - - -

7.1.C Conduct a comprehensive review of the patrol chart to determine if it deploys the patrol force and the supervisors in the most effective manner.

7.2.A Finalize the Managing Performance and Early Intervention policy and procedure that documents the use of Guardian Tracking. ¡

7.3.A Develop a list of critical duties and responsibilities for these positions. - - - - - - - - -

7.3.B Consider requiring that patrol sergeants perform documented visits, preferably in the field, to each subordinate during their shift.

7.4.A Implement a quality control process to ensure compliance with the performance evaluation requirements, and incorporate related duties on the list of supervisor responsibilities. ¡

7.5.ADraft Complaint Initiation Policies and Procedures that (a) call out the different methods of initiating/receiving complaints; (b) allow for the receipt of anonymous complaints; (c) provide for walk-in complaints at UCPD headquarters; (d) prohibit any attempt to dissuade an individual from

¡

7.5.BDraft Complaint Investigation Policies and Procedures that (a) requires the categorization of complaints; (b) defines the workflow of the different categories of complaints from investigation to adjudication; (c) provides time frames for the investigative process; and (d) establishes complaint

7.5.CDraft Complaint Adjudication Policies and Procedures that (a) set forth the standard of proof; (b) prohibit automatic credibility preference being given to an officer’s recitation of facts; (c) define the categories of potential disposition; (d) define the timeframe in which adjudication should be

REPORT CARD MATRIX

2017 2018 2019

Section 7 - Review of Accountability Mechanisms

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec

REPORT CARD MATRIX

2017 2018 2019

Section 7 - Review of Accountability Mechanisms7.6.A

Compile complaint information into a simple database, which can be accessed by the ICS system, and includes several fields (year, date of complaint, nature of the complaint, employee, investigating supervisor, disposition and date completed).

7.7.ADevelop brochures, in hard copy and for inclusion on UCPD’s website, about the complaint process and complaint forms and make such materials available and include as a requirement in a new SOP governing civilian complaints.

7.8.A Consider establishing a subgroup of the CAC to review the UCPD'S investigation of complaints made against employees.

7.9.ACreate a separate SOP detailing how disciplinary matters should be handled by UCPD. Such a procedure should include creating a form that summarizes details of an allegation of misconduct and creates a log listing the number of the issue starting at 001 of year and including the name of

7.10.A Establish an Inspectional Services or Audit unit, reporting directly to the Vice President for Public Safety and Reform. ¡

7.11.A Enter into a voluntary independent monitorship which would provide regular status updates to the Board of Trustees and the public relative to the progression of reform within the Department - - - - - - - - - - -



DATE: APRIL 10, 2018 REC. REF. NO.: 7.2.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD uses Guardian Tracking, a tracking and management software program designed to assist supervisors in their duties of documenting and monitoring their subordinate employee’s performance. Exiger Recommendation (“ER”) UCPD should integrate aspects of the Guardian system with the ICS data system in order to build a comprehensive EWS. MADC Definition of Compliance Compliance with this recommendation will occur when UCPD integrate aspects of the Guardian system with the ICS data system in order to build a comprehensive EWS. UCPD Proffer of Compliance “The Guardian Tracking performance management software is used by the UCPD to document both positive and negative aspects of employee performance. The most recent paid invoice for this software is attached. The UCPD’s use of the Guardian Tracking software was previously hampered by software designs that produced an unwieldy number of categories from which supervisors could select and resulted in inconsistent use across users. In an attempt to remedy these issues and as part of a full review of the capabilities of the Guardian Tracking System, the UCPD designated an internal Performance Improvement Team (PIT) to work collaboratively with the software developer on improvements needed for the division’s advanced analytical demands. Due to the non-renewal of the ICS contract (see DR 0164), rather than explore the potential for interface with the ICS tool as originally recommended, the UCPD PIT instead sought to increase its capabilities within the Guardian Tracking software, including as an early warning system as recommended in ER7.2.A. The Organizational Development Coordinator was charged with chairing the PIT. Other members included: Former Chief Carter, Chief Herold, Acting Assistant Chief Dudley Smith, Captain Carter, Captain Thompson, LT Hoffman, SGT Maxwell, Kimberly Willis, and Lixuan Zheng (IT). The team met on the following dates: 9-13-17, 9-27-17, 10-11-17, 11-7-17, and 11-29-17, while the ODC took the lead on collaborating with the Guardian Tracking representatives in between these meetings. The PIT’s most cumbersome task was to significantly streamline the existing 92 categories, many of which were ambiguous and/or overlapping (see attached). Their work resulted in paring these down into eight main categories with subcategories for each (see attached for revised list). Once the new categories were established, the historical data previously entered was converted into the new categories (see attached for recoding guide).


The PIT team also worked with Guardian Tracking to increase the software’s capabilities as an early intervention system with supervisory alerts to potentially at-risk behavior by officers. The Early Intervention System policy (attached) specifically includes a protocol for the resolution of threshold notifications of potentially at-risk officers on pages 4-5. In PowerDMS, the monitor may access the list of categories and how they contribute to an early intervention flag (i.e., how they are weighted). A screenshot is also attached. The Early Intervention System policy will be disseminated to UCPD personnel after the monitor reviews it and evidence of such will be provided to the monitor via Power DMS at that time. The Managing Performance policy (ER 7.4.A), which will include procedures for monthly evaluations, awards and commendations, will be completed and submitted for assessment in Quarter 6 (April-June 2018) and subsequently disseminated after the monitor reviews it. The PIT team also collaborated with Guardian Tracking to improve the software's capabilities for supervisory evaluations of subordinates. Specifically, they were able to transform supervisory monthly evaluations from two different paper forms to an electronic process completed and stored within the Guardian Tracking System (see attached for monthly evaluation template). Finally, the Guardian Tracking System's staff visited the UCPD HQ to conduct supervisory training on the revised performance management categories and new capabilities of the software on December 14, 2017. This was preceded by an email to supervisors from the ODC to explain the category overhaul, the software improvement process, and provide a link to a training video that would supplement Guardian’s on-site supervisory training (all attached).” Data Reviewed 1. Invoice for Guardian Tracking annual subscription 2. Previous Guardian Tracking Categories 3. Revised Guardian Tracking Categories 4. Guardian Tracking Category Recoding Guide 5. Early Intervention System Policy 6. Notification Threshold Screenshot 7. Monthly Evaluation Template 8. Email to Supervisors 9. Training Video for Supervisors


As is clearly described in the UCPD’s proffer of compliance (above in italics), and was confirmed by the Monitor by way of its collaborative review of and revisions to the Early Intervention System policy and its review of the ample documentation submitted - the UCPD is taking affirmative steps towards the buildout of a comprehensive Early Warning System. While the ICS data will no longer be a factor in the EWS buildout, the Monitor understands that the newly hired Crime Analyst is working on a dashboard to include monthly activities by officer. That type of information/data can and should be used in place of the ICS data in order to get an accurate picture of officer


performance. The Monitor understands that the UCPD has opted to draft a separate policy to cover the Performance Evaluation aspects of the system and ER requirements. While UCPD supervisors are currently completing and documenting the evaluations within the GTS, the policy and protocol has yet to be finalized. The Monitor looks forward to reviewing that policy in the coming weeks once it is submitted for assessment. Next Review The Monitor will again review compliance with ER 7.2.A in Q6 (Q2 2018.)


COMPLIANCE MEMORANDUM DATE: MARCH 31, 2018 REC. REF. NO.: 7.3.B SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding Despite the requirement that written statements of the duties and responsibilities of each specific position be maintained, there appears to be no current listing of duties and responsibilities for Sergeants and Lieutenants other than a general listing of duties for persons seeking the promotion/position. Exiger Recommendation (“ER”) Consider requiring that patrol sergeants (supervisors) perform documented visits, preferably in the field, to each subordinate during their shift. MADC Definition of Compliance Compliance with this recommendation will occur when UCPD considers requiring that patrol sergeants perform documented visits, preferably in the field, to each subordinate during their shift and/or considers alternative plans to ensure appropriate field supervision. Consideration should include a determination of the adequacy of supervisory training. UCPD Proffer of Compliance “On February 16, 2017 Patrol Bureau Commander Captain Jeff Thompson issued a patrol directive regarding the expectation of supervisors to conduct field visits to employees assigned on the shift at least one time during the shift (directive previously provided in Q1). The purpose of these visits is to ensure officers are in compliance with policies, procedures, and practices of the department and are providing the customer service expected of a UCPD employee. These visits are documented in a check box in the “Field Visit” column on the shift line up sheet (see attached line up sheets for each shift from the requested time period). After discussion with the Monitor team regarding their Q1 memorandum of assessment concerns that “the quality of field supervision cannot be measured by a lineup checkmark alone,” UCPD recently implemented a new Shift Supervisor Recap addendum to the regular line up sheets where supervisors document in more detail the many activities and tasks associated with their duties as supervisors (see attached for a sample of revised line up sheets with completed shift summary recaps; also see Supervisory job descriptions submitted to the monitor under Recommendation 7.3.A. in Q3). The shift summary recap process began following the monthly supervisors’ meeting on February 22, 2018, where the Patrol Bureau Commander reviewed with supervisors the following directives associated with the new shift recap:


The recap should be completed by the Sergeant who is responsible for running the shift. If a Lieutenant is running the shift with no Sergeants, then the Lieutenant will be responsible for filling out the recap.

All the new shift line ups/ Supervisor recap sheets are located on the P drive. Items that should be documented in the Recap:

1. Equipment checks 2. Inspections of officers at roll call 3. Off property and Regional Campus checks 4. Field visits were completed 5. Field sick call offs when they come in and document arrange shift coverage if needed 6. Meeting with officers at a scene when they need the attention of a supervisor 7. Any follow up from previous shifts for instance, missing persons, etc. 8. Document any complaints that come into the lobby or over the phone 9. Anything reported to the command staff during your shift, example robberies, serious

nature items, etc. Finally, there have been two recent promotions of supervisors, one sergeant and one lieutenant. Both attended a new supervisor training course provided by the Federal Law Enforcement Training Center (FLETC). This course was selected after completing a course consideration analysis and comparison to other available courses (see documentation provided this quarter under Recommendations 6.14.A/6.15.D). A brief overview of the content of the FLETC training is attached. The new supervisors will each be with a senior supervisor of their rank for a period of time prior to being on their own. The next step toward full compliance with ER 7.3.B will be the internal development of new supervisor orientation training. It is anticipated this will be ready for assessment in Q7.” Data Reviewed 1. Directive to Supervisors 2/6/17 (previously provided) 2. 1st shift line-up sheets from May 1-15, 2017 3. 2nd shift line-up from May 1-15, 2017 4. 3rd shift line-up from May 1-15, 2017 5. FLETC Supervisor Training course description and syllabus overview 6. FLETC certifications 7. Shift Summary Recaps March 1-7, 2018 Prior Assessment In its prior review in Q1 ending March 31, 2017, the Monitor found the UCPD in compliance because the UCPD sergeants were in fact conducting in-field visits. The Monitor did however recommend, and the UCPD agreed, that going forward UCPD would develop an in-house orientation training tailored to cover the specific job requirements and expectations of a UCPD field sergeant. The latter training would be in addition to the OPOTA and FLETC training, and would be provided to newly promoted sergeants.



As described in the UCPD’s proffer of compliance (above in italics), the UCPD promoted one sergeant and one lieutenant who both attended and received a certificate in the “Law Enforcement Supervisor’s Leadership Training Program” through FLETC. The Monitor agrees that this is appropriate and a good choice for foundational training of new supervisors and looks forward to seeing the UCPD specific orientation training for new supervisors in the coming months. During the current period the Monitor reviewed the shift line-ups submitted to assess the newly required supervisor recap completed each shift in response to the Monitor’s recommendation to require field sergeants to document items of note with regard to their duties as a field sergeant. As stated above the Monitor noted that a checkmark alone did not sufficiently communicate the “goings on” (officer actions, significant events or happenings) of a police agency on a daily basis. The UCPD’s response to require the shift supervisor, (sergeant or lieutenant) to specify tasks that were performed, including a note such as “*patrol field visits” (field visit is required in this ER). While the recap information is important to document within a shift log; the recap is not much different than a checkmark. The Monitor’s point of requiring field sergeants to complete a log was not meant to document that type of shift information. Rather, the log should be completed by all field sergeants, every day and should include their insights from their observations as a field sergeant. As examples, a field sergeant might log that he observed an officer who handled a situation with compassion or creatively, or had a positive community contact, or contrarily, could use additional training on vehicle stop tactics, or verbal communication skills. While the Monitor understands that supervisors are able to enter this kind of information on an individual basis within the Guardian Tracking System, the bureau captain does not get the same perception of the daily goings-on of its police department by viewing individual officer records one at a time. The Monitor will have further discussions with the UCPD command staff to brainstorm this concept. Given the orientation training is still under development, the Monitor finds the UCPD in partial compliance at this time. Next Reviews The Monitor will again assess compliance with ER 7.3.B in Q7 (Q3 2018).


COMPLIANCE MEMORANDUM DATE: MARCH 30, 2018 REC. REF. NO.: 7.5.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD policies with respect to complaint receipt, investigation, and disposition are inadequate. Exiger Recommendation (“ER”) UCPD should draft Complaint Initiation Policies and Procedures that (a) call out the different methods of initiating/receiving complaints (by mail, telephone, fax or email and via the UCPD website); (b) allow for the receipt of anonymous complaints; (c) provide for walk-in complaints at UCPD headquarters; (d) prohibits any attempt to dissuade an individual from filing a complaint; (e) requires appropriate notification from UC General Counsel anytime a lawsuit alleging police misconduct is filed; (f) requires notification to UCPD by any officer who is arrested or otherwise criminally charged or the subject of a lawsuit that alleges physical violence, threats of physical violence or domestic violence; (g) requires officers to report the misconduct of other officers including improper use or threatened use of force, false arrest, unlawful search or seizure, or perjury; and (h) allows for the processing of internally generated complaints. MADC Definition of Compliance Compliance with this recommendation will occur when:

1) UCPD implements Complaint Initiation Policies and Procedures; 2) the policies and procedures call out the different methods of initiating/receiving complaints

(by mail, telephone, fax or email and via the UCPD website); 3) the policies and procedures allow for the receipt of anonymous complaints; 4) the policies and procedures provide for walk-in complaints at UCPD headquarters; 5) the policies and procedures prohibit any attempt to dissuade an individual from filing a

complaint; 6) the policies and procedures require appropriate notification from UC General Counsel

anytime a lawsuit alleging police misconduct is filed; 7) the policies and procedures require notification to UCPD by any officer who is arrested or

otherwise criminally charged or the subject of a lawsuit that alleges physical violence, threats of physical violence or domestic violence; and,

8) the policies and procedures require officers to report the misconduct of other officers including improper use or threatened use of force, false arrest, unlawful search or seizure, or perjury;

9) These policies and procedures allows for the processing of internally generated complaints; and

10) These policies and procedures are being followed in practice.


UCPD Proffer of Compliance The UCPD initiated three Complaint Investigations for the period between January 1 and March 31, 2018. Two were Citizen’s Complaints and one was generated internally. The complaints involved two sworn members and one security officer. Each investigation was extended per policy and all were still ongoing at the conclusion of Quarter 5. The initial complaint forms, extension documents, and investigation log have been uploaded to the Smartsheet for the monitor’s review. Completed investigation files will be provided to the monitor as soon as they are available. Attachments 1. Internal Investigations and Complaints Policy 2. Internal Investigations and Complaints training for supervisors 3. Complaint Investigation Supervisor Training sign off sheets 4. Internal Investigations and Complaints training for employees 5. Complaint Investigation Employee Training sign off sheets (forthcoming) 6. Policy Revision Screenshots from Power DMS 7. Form 15A Complaint Form 8. Form 15B Internal Investigation Checklist 9. Form 15C Internal Investigation Employee Complaint Notification 10. Form 15D Waiver or Non-Waiver of Union Representation 11. Form 15E Internal Investigation – Investigation Summary 12. Form 15F Conflict Facilitation Meeting Form 13. Form 15G Complaint Investigation Employee Finding Notification Report 14. Form 15H Complaint Follow Up Letter Template

Prior Assessment of Compliance During 2017, the Monitor assessed the UCPD’s compliance with this ER which included discussions with the OSR and UCPD command staff to ensure agreed upon Methodologies to Aid in the Determination of Compliance (“MADC”); review and evaluation of the applicable policy and protocols to ensure they met best practice standards; assessment of the internal training provided to investigators, supervisors and officers; and, an ongoing assessment of the quality of all 46 internal investigations that occurred in 2017, which includes citizen complaints. Other than some feedback communicated to the UCPD command staff to improve the clarity of investigations, the Monitor found they were suitably complete and closed in a timely manner. Current Assessment of Compliance DW Determination Withheld During this review period, the UCPD submitted three initial complaint intake forms, two of which were initiated by citizens and one of which originated internally. None of the investigations have been completed, but none are overdue - the due date for each having been extended per policy and the intake forms were completed as required. The internal investigations are underway and will be assessed for quality upon completion.


Next Review The Monitor will continue to review all complaints on an ongoing basis to include an assessment of the quality of all complaints to ensure they are investigated to the applicable standards and were conducted in a timely manner. The Monitor will include a report of this assessment each quarter for the remainder of the Monitorship.



DATE: MARCH 20, 2018 REC. REF. NO.: 7.5.C SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD policies with respect to complaint receipt, investigation, and disposition are inadequate. Exiger Recommendation (“ER”) UCPD should draft Complaint Adjudication Policies and Procedures that (a) set forth the standard of proof; (b) prohibits automatic credibility preference being given to an officer’s recitation of facts; (c) defines the categories of potential disposition; (d) and, sets the timeframe in which adjudication should be completed. MADC Definition of Compliance Compliance with this recommendation will occur when:

1) UCPD implements Complaint Adjudication Policies and Procedures to include a Disciplinary Matrix;

2) These policies and procedures set forth the standard of proof; 3) These policies and procedures prohibit automatic credibility preference being given to an

officer’s recitation of facts; 4) These policies and procedures define the categories of potential disposition; 5) These policies and procedures set the timeframe in which adjudication should be

completed; and 6) These policies are disseminated internally to include all appropriate UCPD personnel

(investigators & reviewers). 7) The policies are sufficiently explained to all relevant UCPD personnel (investigators and

reviewers) either as formalized training or an online learning tool (PowerDMS.). UCPD Proffer of Compliance “The Internal Investigations and Complaints policy was previously submitted for assessment by the monitor and found to be in substantial compliance in Quarter 3 of 2017. This policy addresses points A, B, C, and D of the original recommendation 7.5.C. The disciplinary matrix, however, was still in progress at that time. After considerable research into best practice and industry standards regarding discipline for law enforcement, the UCPD has developed the Employee Conduct and Discipline Policy. This policy describes the disciplinary philosophy and process, includes the Rules of Conduct which were previously a standalone SOP, and includes a disciplinary matrix for sustained allegations of rules violations.


Acting Assistant Chief Dudley Smith and Captain Rodney Carter (Standards and Strategic Development Bureau) examined disciplinary processes and matrices from several other departments including: Cincinnati Police Department, Denver Police Department, Portland, Oregon Police Department, and Madison, Wisconsin Police Department. We also looked at other matrices within the University; however, none of those were implemented but rather were in draft form only. Furthermore, in developing this policy, we factored in collective bargaining agreements, University rules, and departmental policies to ensure consistency and compliance. Ultimately, we applied what we found to be fair and impartial industry standards to each of our department’s rules of conduct. This allows equal enforcement of policy, procedures, and rules regardless of rank, seniority, personal demographics, or interpersonal association. UCPD Chief Maris Herold discussed the contents of the disciplinary matrix with supervisory staff and UCPD law enforcement officers at roll calls on January 29, 2018. In addition, the Employee Conduct and Discipline policy will be disseminated to UCPD personnel and signed off on via Power DMS after the monitor reviews and approves it. Power DMS training and testing as to the contents of the policy will accompany its dissemination and evidence of the successful completion of such by UCPD personnel will be provided to the monitor via Power DMS at that time.” Data Reviewed 1. Employee Conduct and Discipline Policy 2. Internal Investigations and Complaints Policy 3. Form 15 Temporary Relief from Duty Prior Assessment of Compliance The Monitor first assessed the UCPD’s compliance with this ER in Q2 ending June 30, 2017 and after reviewing several versions of the Internal Investigations and Complaints Policy, the policy set appropriate standards of proof, prohibited automatic credibility of officer’s recitation of facts, defined the disposition categories, and set timelines for completion of the investigation as required. However, the policy had not yet been disseminated as of the end of that reporting period. During its subsequent review in Q3 ending September 30, 2017, the Monitor found the UCPD in compliance as the finalized policy had been disseminated via its electronic document system, PowerDMS. The Monitor was scheduled to again assess compliance in Q7 to include a review of its training related to the policy. Current Assessment of Compliance

In Compliance

As described above, the Monitor’s previous reviews of this ER involved the UCPD’s revised Internal Investigations and Complaints Policy and found that it contained the specific requirements as described in this ER; however, after reviewing UCPD’s internal investigations and based on subsequent discussions with the UCPD command staff, it became clear that a disciplinary policy and matrix would greatly benefit the agency. As all were in agreement, the UCPD has developed and submitted under this ER, the “Employee Conduct and Discipline Policy” which includes the aforementioned matrix. To reiterate the UCPD’s points described in their


proffer (above in italics), the concept of using a disciplinary matrix to guide police executives during the adjudication process, specifically during the penalty phase of sustained allegations of misconduct, is a standard in national best police practices. The use of a matrix to set initial parameters when misconduct warrants a suspension, demotion, or termination; and requiring police executives to explain any departures from those parameters, helps to ensure consistency from case to case, and provides for transparency and overall confidence in the disciplinary process throughout the department and community. The Monitor verified that the revised policy has been disseminated to its personnel through a review of its electronic document system, PowerDMS. Next Review The Monitor will again assess compliance with this ER during Q7 (Q3 2018) which will include a review of any training provided to its investigators and reviewers of investigations.

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec

8.1.A Recognize the essential nature of the community affairs function within the UCPD and appropriate resources dedicated to it.

8.1.B The Community Affairs organization should be elevated to a more prominent position in the organization and should be staffed appropriately. - - - - - - - - - - -

8.1.C Create a separate Community Affairs Office which reports directly to the Chief, thereby exercising greater authority across the organization. - - - - - - - - - - -

8.1.D Rescind the existing SOPs and write new policies and procedures to reflect the new structure and mission of the unit. - - - - - - - - -

8.1.E Consider whether the Victim Services Coordinator belongs in the Community Affairs Office or whether it might be more appropriately housed elsewhere within UCPD or the University. - - - - - - - - - - -

8.2.A The Community Affairs Office should be managed by a supervisor with formal operational authority to manage all of the various components of the Community Affairs mission. - - - - - - - - - - -

8.2.BThe supervisor position could either be a civilian title, e.g., Director, or a uniformed title, e.g., Captain but should be of sufficient stature as to be able to coordinate resources across the organization, particularly those resources that are not specifically assigned to Community Affairs

- - - - - - - - - - -

8.2.C Staff the Community Affairs Office with a minimum of two officers whose sole responsibilities are community affairs duties. - - - - - - - - - - -

8.2.D Consider assigning officers as community liaisons to designated community groups. - - - - - - - - - - -

8.2.E Consider revising the provision of the Collective Bargaining Agreement that prescribes a four-year rotation period for CAO’s. ¡

REPORT CARD MATRIX

2017 2018 2019

Section 8 - Review of Community Engagement, Problem-Oriented Policing, and Crime Prevention

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

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Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

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REPORT CARD MATRIX

2017 2018 2019

Section 8 - Review of Community Engagement, Problem-Oriented Policing, and Crime Prevention 8.2.F

Design and implement a selection process for the Community Engagement Officers which evaluates candidates against the specific qualifications necessary for effective performance of the function, and includes the opportunity for community and student body input.

- - - - - - -

8.3.A Provide Community Affairs Office staff with specialized training on public speaking, crime prevention, labor relations, and social media

8.4.A Establish the supervisory position of Event Coordinator, with appropriate staff - - - - - - -

8.5.A Train personnel in a community policing problem solving model. - - - - - - - - - - -

8.5.B Consider adopting the CAPRA community policing problem solving model. - - - - - - - - - - -

8.5.C Develop a problem-solving approach to chronic crime and disorder problems.

8.5.D If UCPD continues to patrol off campus, then problem-solving groups should also involve community residents and CPD.

8.5.E Develop a policy that outlines the problem-solving program, and contain clear roles, responsibilities and expectations regarding the UCPD’s problem-solving efforts.

8.6.A Increase the number of CCTV cameras deployed in both the on and off campus communities, and collaborate with the CPD to identify strategic locations to place the additional cameras. - - - - - - -

8.6.BInstitute a ‘Safe Haven’ program whereby local businesses register with UCPD, agree to display a distinctive logo on their storefronts that identifies them as a Safe Haven, and pledge to assist University affiliates in distress.

8.6.C Consider implementing Operation Blue Light, a program that authorizes UCPD personnel to mark property with an invisible ink discernible only under a special blue light.

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec

REPORT CARD MATRIX

2017 2018 2019

Section 8 - Review of Community Engagement, Problem-Oriented Policing, and Crime Prevention 8.6.D Consider implementing Operation ID, a nationwide program that aims to deter theft by permanently

identifying valuable property with an indelible, inconspicuous, specially assigned number.

8.6.EConsider implementing PC PhoneHome/Mac PhoneHome, a program that allows authorities to locate a lost or stolen computer by identifying its location when the machine is connected to the Internet.

8.6.F Consider employing Stop Theft Tags, which possess a unique ID number that is entered into the STOPTHEFT worldwide database, and allow lost or stolen property to be reunited with its owner.

8.6.G Look into Bicycle Registration, where a permanent decal is affixed to the bicycle, thus giving it a unique ID number that is registered with the UCPD.



DATE: MARCH 30, 2018 REC. REF. NO.: 8.2.F SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding Beyond the Director of Community Police Relations, daily supervision and leadership of the Community Affairs Program currently relies on the good faith efforts and initiative of the Community Engagement Officer and the Public Information Officer, both of whom lack the formal responsibility or authority to be able to implement ideas and programs effectively. Exiger Recommendation (“ER”) UCPD should design and implement a selection process for the Community Engagement Officers which evaluates candidates against the specific qualifications necessary for effective performance of the function, and includes the opportunity for community and student body input. MADC Definition of Compliance Compliance with this provision will be achieved when:

1) The UCPD designs and implements a selection process for the Community Engagement Officers; 2) The UCPD evaluates candidates against the specific qualification necessary for effective

performance of function; and, 3) The UCPD evaluation process includes the opportunity for community and student body

input.

Proffer of Compliance “The selection process for Community Engagement Officers is described on page 3 in the UCPD Special Assignments Policy (attached), and referenced in the Community Affairs Section Protocol (attached, page 2). The selection process described in the Special Assignments policy specifically includes the opportunity for community and student body input. The Special Assignments policy will be disseminated after the monitor’s review and evidence of such will be provided to the monitor via Power DMS at that time. The Community Affairs Section Protocol was previously approved by the Monitor in Q1, but has been re-disseminated to UCPD personnel as of 2/21/18 to reflect recent revisions; evidence of such will be provided to the monitor via Power DMS prior to the end of Q5. Article 40 of the ULEO collective bargaining agreement and Article 14 of the supervisors’ collective bargaining agreement (attached) also describes the selection process for Special Assignments.

Currently, the CAS is supervised by Lieutenant David Hoffman and staffed by Officer Douglas Barge (in the unit since 2014) and Officer James Vestring (in the unit since 2016). The job descriptions for both the supervisor and officers assigned to this unit were previously submitted to the monitor in conjunction with the assessment of ER 8.2.C. No officers have been selected to this


assignment since the new process was implemented. Data Reviewed 1. Community Affairs Section Protocol 12.2.100 2. Special Assignments Policy 3.2.101 3. Article 40, ULEO Collective Bargaining Agreement and Article 14, Supervisor Collective

Bargaining Agreement


As described in the UCPD’s proffer of compliance (above in italics), and verified by the Monitor’s review of the documentation submitted, the UCPD has designed and disseminated a policy to meet the requirements of this ER which includes an appropriate selection process that provides for community and student body input. The Monitor is pleased that the UCPD has acknowledged the significance of the Community Engagement Officer’s role in the organization. Next Review No further review of this ER is necessary.



DATE: MARCH 30, 2018 REC. REF. NO.: 8.4.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD does not have a dedicated Event Coordinator who would be charged with primary responsibility for public safety planning for, resourcing of, and response to the myriad of events occurring on campus. Exiger Recommendation (“ER”) UCPD should establish the supervisory position of Event Coordinator, with appropriate staff, whose responsibilities would include, but not be limited to: Review event permit applications in the University database and communicate with event

planners to address security and safety concerns. Conduct a risk analysis of proposed special events to determine the mitigation actions required

including the number and type of security staff needed. Coordinate provision of security staffing and operations supporting events with university

departments that facilitate events, including Transportation, Fire Safety, Facilities Management, Campus Activities, Hospitality, and Campus Filming.

Represent the department in regular campus event and stadium event management meetings, and attend occasional production meetings, event walk-throughs, or meetings with individual event organizers.

Plan and assign department staffing for events and security details. Among other things, to post details of the assignments in the daily Overtime Update.

Prepare detailed written instructions/post orders for officers assigned to event or security details, and write operations plans for large or complex event details.

Prepare and send cost estimates and invoices to event organizers for department event staffing, and assist department accounting staff in following up with event organizers regarding unpaid invoices.

Serves as officer-in-charge for major event details conducting officer briefings and managing the events, such as student Move-in Day, football games, student concerts, Commencement and other major university events.

Coordinate and liaison with outside law enforcement and public safety agencies regarding university events with wider impact, or community events that may impact both the university and surrounding community.

Serve as UCPD point-of-contact for dignitary visits to the campus, coordinate with public or private security personal protection details (including Secret Service and protective details for other elected officials), and plan and arrange department staffing as needed.


Serve as department point-of-contact for protests and demonstrations, and plan or coordinate department staffing as needed.

Review and provide department approval for requests to serve alcohol at events at campus locations not licensed to do so, in coordination with Hospitality Services.

Supervise any event coordination staff. MADC Definition of Compliance Compliance with this provision will be achieved when: 1) The UCPD establishes the supervisory position of Event Coordinator; 2) The Event Coordinator is supported by an appropriate staff; and 3) The Event Coordinator is responsible for the requirements specified in the ER among other things.

Proffer of Compliance “The UCPD has created a supervisory position at the rank of Lieutenant that is responsible for Inspections and Special Event Planning. Attached is the supervisory job posting email sent from the Associate Director of Business Affairs to all UCPD lieutenants on January 24, 2018. Also attached is the job description for the advertised open supervisory position. Only one candidate applied for the open position; as such, the interview process was waived. Captain Thompson completed the attached Form 5 with the recommendation to select Lieutenant Timothy Barge, which was approved by Chief Herold. This appointment is effective as of 2/26/2018. Responsibility for UCPD Special Event coordination is the responsibility of the aforementioned lieutenant, who is supported by the Assistant Coordinator for Public Safety Events (a non-sworn position held by Lauren Bycynski) and the Special Event Detail Coordinator (a sworn officer position held by ULEO3 Lori Cronin). The job descriptions for each of these two positions are attached. Some of the specific responsibilities included in the original Exiger recommendation are included on one of the support staff’s job descriptions, rather than the lieutenant’s, but the supervisor is ultimately responsible for all tasks and assigned responsibilities of his subordinates.” Data Reviewed 1. Supervisory Job Posting Email 2. Job Description: Lieutenant, Inspections and Special Event Planning 3. Form 5, Supervisor Selection 4. Job Description: Assistant Coordinator, Public Safety Events 5. Job Description: Special Event Detail Coordinator Current Assessment of Compliance

In Compliance

As described in the UCPD’s proffer of compliance (above in italics), and verified by the Monitor’s review of the documentation submitted, the UCPD has established the supervisory position of Event Coordinator who is supported by an appropriate staff and is responsible for the requirements


specified in the ER. The Monitor noted that several of the specified functions are being performed by the Event Coordinator staff but irrespective of who performs the task, both the position description and the policy support the concept that the Event Coordinator is ultimately responsible for the functions. Next Review No further review of this ER is necessary.



DATE: MARCH 13, 2018 REC. REF. NO.: 8.6.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding While the UCPD currently has a number of effective crime prevention initiatives in place, additional programs should be implemented. Exiger Recommendation (“ER”) UCPD should increase the number of CCTV cameras deployed in both the on and off campus communities, and should collaborate with both UCPD and CPD investigators to identify strategic locations to place the additional cameras. MADC Definition of Compliance Compliance with this provision will be achieved when: 1) UCPD increases the number of CCTV cameras deployed in both the on and off campus communities; and, 2) UCPD collaborates with CPD investigators to identify strategic locations to place the additional cameras. Proffer of Compliance “UCPD has installed 3 additional cameras and 4 more are in progress as detailed in Memo 10.3.A. Input from CPD resulted in the installation of the UPARK camera which overlooks the Shell station on Calhoun St. and surrounding area. UCPD has decided not to install off campus cameras at this time due to the complexity and cost to network them back to campus. In discussions between the UC Network Operations Center (NOC) and Diane Brueggemann in August 2016, the options to network off campus included private fiber, VPN, and firewall open ports. Due to the costs and/or security vulnerabilities these options presented and the readily available option to view CPD cameras no further action was taken to investigate installing cameras off campus. In follow up discussion on January 31, 2018 between Diane Brueggemann and the NOC, there is no change to the options or cost/security concerns from the August 2016 information. As of October 11, 2016, UCPD has had access to view city cameras via an app installed on iPads which can be connected to large monitors. CPD cameras have been strategically placed to cover potential problem areas. CPD added several new cameras in preparation for the Tensing trial in fall 2016. Fifteen of the city cameras have views in the area surrounding UC. In conversations with city camera representatives, it was noted that these cameras are wireless and can be moved to other areas as requested by UCPC and CPD investigators and administration.”


Data Reviewed 1. Camera Committee Report-03012016 2. Camera Committee Report-01162018 3. Project Request Form: Installation of 4 permanent cameras 4. Purchase Order: Two wireless cameras


As described in the UCPD’s proffer of compliance (above in italics), the UCPD has not only installed additional cameras on campus but is also engaged in a continual collaboration and coordination with the Cincinnati Police Department (CPD) to ensure the most cost efficient and secure use of the cameras as surveillance. The Monitor commends the UCPD for its resourcefulness in using the available resources. Next Review No further review of this ER is necessary.

Q1:Jan-Mar

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Q12:Oct-Dec

9.1.A Establish clearly written policies and procedures based upon existing best practices used by campus police departments.

9.1.B Include in the new policy a list of generalized signs and symptoms of behavior that may suggest mental illness. - - - - - - - - - -

9.1.CInclude in the new policy should a list of indicators that will help an officer determine whether an apparently mentally ill person represents an immediate or potential danger.

- - - - - - - - - -

9.1.D The new policy should include guidelines for officers to follow when dealing with persons they suspect are mentally ill. - - - - - - - - - -

9.1.EReview applicable reports from other jurisdictions, including the USC and LA Mental Health Advisory Board, and incorporate suggestions from those reports in policies, procedures and training.

- - - - - - - - - -

9.2.A Implement a Student Concerns Committee that consists of first responders and those potentially in a position to take notice of irrational student behavior. - - - - - - - - - -

9.2.BThe Student Concerns Committee should meet on a weekly basis to discuss issues that took place during the previous week and are potentially related to mental health, and collaboratively create a plan of action.

- - - - - - - - - -

9.3.A Ensure that additional officers trained in crisis intervention are deployed during potential peak periods of stress for students. - - - - - - - -

9.4.A Provide all sworn officers with CIT, and with documented refresher training on a bi-annual basis.

9.4.BUtilize UCMC experts to educate officers on issues specific to student populations, particularly those within the University community, including sensitivity training highlighting the position of students who are away from home

- - - - - - -


Section 9 - Review of Encounters with Individuals with Mental Health Concerns

Q1:Jan-Mar

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Section 9 - Review of Encounters with Individuals with Mental Health Concerns 9.4.C

Consider establishing proactive response teams pairing an on-call UCMC clinician with a law enforcement officer to provide emergency field response to situations involving mentally ill, violent or high risk individuals.

- - - - - - - - - -

9.5.A After every encounter with an individual suffering from a mental illness, UCPD should mandate detailed reporting for inclusion in the ARMS system. ¡

9.5.B In order to improve performance, annually audit the handling of mental health-related calls and incidents for that year. ¡


COMPLIANCE MEMORANDUM DATE: MARCH 15, 2018 REC. REF. NO.: 9.4.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding While UCPD’s current mental health training practices exceed those of most other Campus Law Enforcement Agencies, there are additional measures that represent best practices in this area. Exiger Recommendation (“ER”) All sworn officers should trained and certified in Crisis Intervention, with documented refresher training on a bi-annual basis. MADC Definition of Compliance Compliance with this provision will be achieved when: 1) UCPD implements a policy requiring that all officers are trained and certified in Crisis Intervention; 2) UCPD implements a policy requiring that all officers receive documented refresher training on a biennial basis; and, 3) The training meets best practices in the industry. UCPD Proffer of Compliance “The UCPD Training Plan (attached), referenced in the Training and Professional Development Policy (attached), requires all new officers be trained in Crisis Intervention within the first 6-9 months of their first year of employment and requires officers to complete refresher training on a biennial basis following the initial training. Page 9 of the Mental Health Response Policy (attached) similarly requires that “Police personnel will receive training on Mental Health Response as part of their initial training and personnel assigned to patrol will receive refresher training at least every two years thereafter.” Although not required by the original Exiger Recommendations, the UCPD’s Annual Training Plan also mandates this training for its dispatchers and makes the training available to its security officers as well. The attached 2017 Continued Professional Training (CPT) spreadsheet and individual certificates shows the in-service training of sworn law enforcement officers, dispatchers, and security officers in 2017. The majority of UCPD’s sworn personnel were trained during 2017 and March 2018. Currently, at the conclusion of Quarter 5, 61 of 63 sworn officers are CIT-trained.1 Two additional



sworn officers are scheduled for September and November. However, ten sworn officers that were previously CIT trained are overdue for their every 2 years refresher training. At this time the 4-hour refresher course is expected to occur prior to the end of 2018. It is expected that greater than 94% of sworn officers, who are required to attend this training or its refresher training, will have completed it by Q8. UCPD shift lineup sheets denote all CIT-trained personnel. A sample of line-up sheets may be provided to the monitor upon request. The two recent apprentice hires will receive 20 hours of Crisis Intervention training as part of their academy training. The academy course materials on this topic are attached. Further, as evidence of their enrollment in the CPD academy, the apprentices’ offer and acceptance letters are attached, which specifically state they will be attending the academy as part of the offer letter. Currently, 10 of 13 dispatchers and 6 of 22 security officers are CIT trained. Due to the limited availability of this course from the outside vendor (Mental Health America of Northern Kentucky and Southern Ohio), the majority of these non-sworn personnel will not be completed until later in 2018, occurring throughout the year on the following dates: May 7-11, September 17-21, and November dates TBD. The contents of the CIT in-service training are attached and include a number of issues specific to student populations. This training, as noted above, is being provided by Mental Health America of Northern Kentucky and Southern Ohio rather than the UCMC because of the quality of previous trainings provided by the vendor to the UCPD and their consistency with best practices and expertise in the subject matter.” Data Reviewed 1. Training Plan 2. Training and Professional Development Policy 3. Mental Health Response Policy 4. 2017 CPT Spreadsheet 5. 2017 CIT Training Certificates 6. CPD Academy Crisis Intervention Training Materials 7. Certificates for those attending March in-service CIT training (forthcoming) 8. In-Service CIT Curriculum including:

CIT: Agitated Psychotic Event CIT: Child and Adolescent CIT: Developmental Disabilities CIT: De-escalation Techniques CIT: Homeless CIT: Suicide CIT: Veteran Affairs CIT: Writing an Effective Hold



Partial Compliance

As described in the UCPD’s proffer of compliance (above in italics), and which was confirmed by the Monitor’s review of the documentation submitted, a large portion of the UCPD sworn officers and many of the dispatchers and security officers received Crisis Intervention Training in 2017. The training curriculum reviewed and attended was found to be sufficient, included realistic, scenario-based training, and covered topics necessary to ensure officers are equipped as first responders when contacting people who may be undergoing a mental health crisis. While the UCPD has demonstrated that CIT Training is in fact part of the new hire and in-service training program, ten sworn officers were certified prior to 2017 and should have, but did not, receive the required refresher training. The Training Unit has indicated that the planning for the refresher training is underway and will consist of a 4-hour block but has not yet been scheduled due to the many other competing training priorities during this annual period. The UCPD can obtain substantial compliance once quality in-service/refresher training has been developed, scheduled and attended by officers who have not attended training for over two years. Next Review The Monitor will again report on the status of compliance of this ER in Q8 (Q4 2018).


COMPLIANCE MEMORANDUM DATE: MARCH 15, 2018 REC. REF. NO.: 9.4.B SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding While UCPD’s current mental health training practices exceed those of most other Campus Law Enforcement Agencies, there are additional measures that represent best practices in this area. Exiger Recommendation (“ER”) UCPD should utilize UCMC experts to educate officers on issues specific to student populations, particularly those within the University community. This should include sensitivity training, highlighting the challenges faced by students who are away from home for the first time. MADC Definition of Compliance Compliance with this provision will be achieved when: 1) UCPD implements a policy requiring educating officers on issues specific to student populations; 2) The policy requires that UCMC experts are being used to conduct the training; and 3) The training includes sensitivity training and highlights the challenges faced by students who are away from home for the first time. UCPD Proffer of Compliance “The UCPD Training Plan (attached), referenced in the Training and Professional Development Policy (attached), requires all new officers be trained in Crisis Intervention within the first 6-9 months of their first year of employment and requires officers to complete refresher training bi-ennially following the initial training. Page 9 of the Mental Health Response Policy (attached) similarly requires that “Police personnel will receive training on Mental Health Response as part of their initial training and personnel assigned to patrol will receive refresher training at least every two years thereafter.” Although not required by the original Exiger Recommendations, the UCPD’s Annual Training Plan also mandates this training for its dispatchers and makes the training available to its security officers as well. The attached 2017 Continued Professional Training (CPT) spreadsheet and individual certificates shows the in-service training of sworn law enforcement officers, dispatchers, and security officers in 2017. The majority of UCPD’s sworn personnel were trained during 2017 and March 2018.


Currently, at the conclusion of Quarter 5, 61 of 63 sworn officers are CIT-trained.1 Two additional sworn officers are scheduled for September and November. However, ten sworn officers that were previously CIT trained are overdue for their every 2 years refresher training. At this time the 4-hour refresher course is expected to occur prior to the end of 2018. It is expected that greater than 94% of sworn officers, who are required to attend this training or its refresher training, will have completed it by Q8. UCPD shift lineup sheets denote all CIT-trained personnel. A sample of line-up sheets may be provided to the monitor upon request. The two recent apprentice hires will receive 20 hours of Crisis Intervention training as part of their academy training. The academy course materials on this topic are attached. Further, as evidence of their enrollment in the CPD academy, the apprentices’ offer and acceptance letters are attached, which specifically state they will be attending the academy as part of the offer letter. Currently, 10 of 13 dispatchers and 6 of 22 security officers are CIT trained. Due to the limited availability of this course from the outside vendor (Mental Health America of Northern Kentucky and Southern Ohio), the majority of these non-sworn personnel will not be completed until later in 2018, occurring throughout the year on the following dates: May 7-11, September 17-21, and November dates TBD. The contents of the CIT in-service training are attached and include a number of issues specific to student populations. This training, as noted above, is being provided by Mental Health America of Northern Kentucky and Southern Ohio rather than the UCMC because of the quality of previous trainings provided by the vendor to the UCPD and their consistency with best practices and expertise in the subject matter.” Data Reviewed 1. Training Plan 2. Training and Professional Development Policy 3. Mental Health Response Policy 4. 2017 CPT Spreadsheet 5. 2017 CIT Training Certificates 6. CPD Academy Crisis Intervention Training Materials 7. Certificates for those attending March in-service CIT training (forthcoming) 8. In-Service CIT Curriculum including:

CIT: Agitated Psychotic Event CIT: Child and Adolescent CIT: Developmental Disabilities CIT: De-escalation Techniques CIT: Homeless CIT: Suicide CIT: Veteran Affairs



CIT: Writing an Effective Hold Current Assessment of Compliance

In Compliance As described in the UCPD’s proffer of compliance (above in italics), the UCPD opted to use experts from Mental Health America of Northern Kentucky and Southern Ohio rather than from UCMC. The Monitor’s review of the presentation material confirmed that the vendor used provided information as specifically required by this ER and based on best practices in appropriate topic areas such as suicide, homelessness, persons with developmental disabilities, and other mental health situations. Next Review No further review of this ER is needed.

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec

10.1.A Re-deploy CEDs. - - - - - - - -

10.1.BReview policies and procedures related to the use of CEDs to include when the use of the devices is authorized and the allowable number of discharges of the device.

- - - - - - - - -

10.1.CDevelop intensive training on the use of CEDs and the relevant policies, including scenarios in which the utilization of CEDs is appropriate and those instances where it is not.

10.1.DDesignate a CED training officer, who should receive training as a trainer and whose responsibilities should include remaining current on all relevant literature and data on the use of CEDs.

¡

10.2.AWork with CPD and appropriate neighborhood organizations to provide significantly greater deployment of video surveillance in the off-campus patrol areas.

- - - - - - - - - - -

10.3.A Conduct a review of all existing video surveillance equipment in conjunction with the exploration of an off-campus video system. - - - - - - -

10.4.A Develop or adopt appropriate training for the use of the batons, and ensure that every member of UCPD receive such training.

10.5.A Evaluate and choose an automated commercial off-the-shelf product for tracking of all equipment. - - - - - - - - -

10.6.A Evaluate the need and potential utilization of the bomb robot. - - - - - - - - - - -

10.6.BIf there is justification to retain the robot, appropriate initial and refresher training and qualification of a select group of sworn officers on the utilization of the robot and related skill sets including bomb disposal should be developed and deployed.

- - - - - - - - - - -


Section 10 - Review of Equipment

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec


Section 10 - Review of Equipment10.7.A Evaluate the need and potential utilization of the sniper rifle. - - - - - - - - - - -

10.7.BIf there is justification to retain the rifle, appropriate initial and refresher training and qualification of a select group of sworn officers on the utilization of the rifle should be developed and deployed.

- - - - - - - - - - -

10.8.AConsider installing in-car video as an adjunct to the current deployment of body cams, providing for potential additional views of and redundancy in any critical incident.

¡

10.9.AWork with the Director of Emergency Management to build out a dedicated Emergency Operations Center, designed to facilitate planning and response to both planned and unplanned campus events in coordination with other federal,

- - - - - - - - -



DATE: MARCH 13, 2018 REC. REF. NO.: 10.3.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding Components of the currently deployed on-campus video surveillance system should be upgraded. Exiger Recommendation (“ER”) Conduct a review of all existing video surveillance equipment in conjunction with the exploration of an off-campus video system. MADC Definition of Compliance Compliance with this recommendation will be achieved when: 1) UCPD completes a review of all existing video surveillance equipment; and, 2) UCPD considers the creation of an off-campus video system. Proffer of Compliance “In February and March of 2016 Public Safety conducted a review of camera equipment with a committee composed of representatives from Technical Services, Crime Prevention, Dispatch, and Patrol. Input was also considered from conversations with CPD. The camera committee report is attached. In September 2016, as a result of the report, UC added 3 cameras on campus: Top of UPARK, Crosley Tower, and Teachers College. The recommended camera on the pole at the main gate was changed to Teachers College by the architect due to infrastructure challenges with the pole installation. These cameras provide campus views as well as views of surrounding city streets and businesses. The current video management system (DVTEL/FLIR) was upgraded to the latest version in December of 2016. The most recent camera study was conducted in December 2017 and January 2018 to further fill in gaps in camera surveillance. This study concentrated on gaps in coverage not only in day to day normal campus operations but also for special events. This study resulted in a plan to add 4 permanent cameras and 12 wireless relocatable cameras. The installations are in process by Planning, Design, and Construction (see attached Project Request Form) and two of the 12 wireless cameras have been ordered (see attached Purchase Order). These two cameras will be tested for functionality prior to ordering the additional ten wireless cameras. As noted in the memo for 8.6.A, the creation of an off-campus video system has been tabled in favor of UCPD gaining access to CPD cameras in areas surrounding UC campus.”


Data Reviewed 1. Camera Committee Report-03012016 2. Camera Committee Report-01162018 3. Project Request Form: Installation of 4 permanent cameras 4. Purchase Order: Two wireless cameras


As described in the UCPD’s proffer of compliance (above in italics), the UCPD has conducted a full review of all video camera surveillance system to include the consideration of an off-campus system. As mentioned in the Monitor’s review of ER 8.6.A which recommends an increase in the number of CCTV cameras, the UCPD has not only installed additional cameras strategically on campus but is also engaged in a continual collaboration and coordination with the Cincinnati Police Department (CPD) to ensure the most cost efficient and secure use of the cameras as surveillance equipment. The Monitor commends the UCPD for its resourcefulness in using the CPD cameras available. Next Review No further review of this ER is needed.


COMPLIANCE MEMORANDUM DATE: MARCH 28, 2018 REC. REF. NO.: 10.8.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD does not currently have video recording capabilities in their vehicles. Exiger Recommendation (“ER”) UCPD should consider the installation of in-car video as an adjunct to the current deployment of body cameras, providing for potential additional views of and redundancy in any critical incident. MADC Definition of Compliance Compliance with this provision will be achieved when: 1) UCPD gives meaningful consideration to installing in-car video as an adjunct to the current deployment of body cameras; and 2) If UCPD determines that in-car video is appropriate, it installs video recording devices in all of its patrol vehicles. UCPD Proffer of Compliance “In an effort to fulfill its commitment to professionalism, accountability and transparency, the University of Cincinnati Police Division decided to purchase 24 Axon Fleet cameras earlier in 2017. The quote, purchase order, and signed contract for this equipment purchase were previously submitted to the monitor in Q4. The In-Car Video Recording System is a video and audio recording system assigned to each patrol vehicle while in use for police activity. The IVRS is meant to supplement the officer’s visual perspective of an incident, thus allowing the officer a greater opportunity to capture details otherwise missed during times his/her attention might be focused elsewhere. The policy governing the use, training, and review of the new equipment and its recordings (In-Car Video Recording System Policy 9.1.701) was previously submitted to the monitor in Quarter 4. After some collaborative revisions during that quarter, the policy was fully disseminated to UCPD personnel in March 2018. Evidence of such is available to the monitor via Power DMS. However, as the UCPD prepared to train its personnel on the use of the equipment and the new policy, the need for additional policy revisions was identified. The policy will be redisseminated to UCPD personnel after the monitor reviews the revised policy in Quarter 6. Due to the UCPD’s familiarity with the body worn cameras provided by the same manufacturer and the In-Car video cameras’ similarity to the body worn cameras, officers will be trained on the use of this equipment via Roll Call Training. A previous version of the planned training was provided to the monitor and an updated version of the training slides reflecting the above-noted


policy revisions will be submitted in Q6; sign off rosters will be provided to the monitor after the completion of this training in Q6. The hardware and docking stations have been fully installed. The monitor team was given a demonstration of the equipment during their on-site visit in February and has been provided access to Evidence.com where videos will be uploaded once the IVRS is full operational (expected early Q6). The monitor may also verify the installation of the equipment through that access (see attached list). Due to the software vetting process that is occurring in another local police agency, the software cannot currently be installed on the Division’s existing MDCs (mobile digital computers). The Division anticipates the new MDCs (see attached MDC replacement project information), on which the software can be installed, will be received in August or September 2018. In the interim, in-car video recording cameras will be issued at roll call and signed back in at the end of shift. As with body cams and according to the IVRS policy, in the absence of the automatic Wi-Fi upload, officers will upload, charge and store their IVRS in the docking stations located in the squad room before securing for the day. Data Reviewed 1. In-Car Video Recording System Policy 9.1.701 2. Roll Call Training slides – In Car Video Recording System 3. Evidence.com Equipment Verification List 4. MDC Replacement Project Prior Assessment In its prior review in Q4 ending December 31, 2017, the Monitor found the UCPD in partial compliance as the In-Car Video Recording System (IVRS) had not yet been fully implemented nor had the training been delivered. Current Assessment of Compliance

Partial Compliance

During the current quarter, as described in the UCPD’s proffer of compliance (above in italics), the UCPD continued the process of implementing the In-Car Video Recording System (IVRS) to include installation of the equipment and drafting of the policy. During its initial review of the IVRS policy, the Monitor noted several areas for clarification and revision which was accomplished via the collaborative process with the Organizational Development Coordinator. The finalized policy was subsequently reviewed and found to be consistent with best practices. While the UCPD is making forward progress with the system, the Monitor again finds the UCPD in partial compliance since the IVRS policy and software are not fully implemented nor has the training been completed. Next Review The UCPD’s compliance with this ER is again scheduled in Q6 for the period ending June 30, 2018 to assess implementation of the policy, working ICVR systems, and the training.

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec

11.1.A Require that each officer create a test recording before they deploy to the field each day to ensure the body camera is functional.

11.1.BRe-write Body cam policy to address how to specifically handle video in use of force (i.e., who takes custody of the camera, who reviews the video, when should an officer review video, etc.).

- - - - - - - -

11.1.CThose developing the body camera policy should continue to refine and improve the policy as lessons are learned, and collaborate with other agencies that have deployed cameras to learn from those experiences.

11.1.D Consider including the body camera policy as a topic of discussion in community forums, student body meetings, etc. - - - - - - - - - - -

11.2.AConsult a subject matter expert to assist in negotiating an agreement for cameras and storage so that it includes discounted pricing; a “termination for convenience” clause; the appropriate level of on-site training and support from Taser; etc.

- - - - - - - - - -

11.2.B UCPD should identify any video in storage that must be retained into the future, and work with Taser to migrate that video to Evidence.com for long-term storage. - - - - - - - - - -

11.2.C Consider engaging a provider for additional system training, to ensure the Department is making full use of its video management system - - - - - - - - - - -

11.3.AModify the practice of tagging video with only a suspect’s name. Instead, it should consider utilizing additional identifiers, such as the CAD incident number and/or an RMS record number.

11.3.B Consider contracting with a vendor that allows for CA integration with its video management system. - - - - - - - - - - -

11.4.AEnsure that all business/functional requirements for ARMS are clearly documented and that testing of the upgraded ARMS is conducted against those requirements before the system is accepted.

REPORT CARD MATRIX

2017 2018 2019

Section11-ReviewofTechnology

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec

REPORT CARD MATRIX

2017 2018 2019

Section11-ReviewofTechnology11.5.A Consider implementing an ARMS Mobile Product on MDCs and/or tablets to

enable officers to complete reports from the field. - - - - - - -

11.6.A Add a radio console to the third position so it can be in a position to handle multiple calls/traffic at one time. - - - - - - - - - - -

11.7.A Implement a 9-1-1 system that provides the actual geo location of the call, as is standard in dispatch centers across the country.

11.8.A Explore ways to expand adoption of Live Safe on campus and potentially off-campus as well.

11.9.A Identify funding for a replacement card access system. - - - - - - - - -

11.9.BPSTS should document the requirements for a replacement system, which should include a plan for how to integrate the card access system with an existing key management system that was developed in-house.

11.10.A Consider adding one IT Project Manager to PSTS staff to ensure large IT projects are implemented according to IT management best practices. - - - - - - - - - -

11.10.BPSTS should engage in a study to determine the appropriate IT staffing levels. It appears that additional Technicians are likely required to support the IT needs of the Department.


COMPLIANCE MEMORANDUM DATE: MARCH 15, 2018 REC. REF. NO.: 11.1.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD has implemented body cameras which already places it ahead of most University police departments. The body camera policy, however, does not address a number of issues, including how video is handled subsequent to an incident involving a shooting or serious use of force. Exiger Recommendation (“ER”) UCPD should implement a requirement that each officer create a test recording before they deploy to the field each day to ensure the camera is functional. If a camera is not functioning properly, the officer should be required to check out a new, functioning camera before he/she deploys to the field. MADC Definition of Compliance Compliance with this provision will be achieved when:

1) UCPD implements a policy requiring officers to create a test recording each day before being deployed and if a camera is not functioning appropriately, an officer will check out a new functioning camera; and

2) The policy is disseminated internally to include all appropriate UCPD personnel. 3) The topic was sufficiently explained to all relevant UCPD personnel. Sufficiency of

explanation will depend upon the topic and can include, but is not limited to, formalized training, roll-call presentations, and online learning tools.

4) The policy is being followed in practice. Proffer of Compliance from UCPD “The monitor previously assessed the content of the Body Worn Camera Digital Recording System Policy in Q2 and found the UCPD to be “Partial Compliance” for ERs 11.1.A and 11.1.B pending the policy’s dissemination. It was scheduled for reassessment in Q4 because it was expected that the policy would be fully disseminated to UCPD personnel by that time. In fact, previous versions of that policy were fully disseminated in August and November (see Power DMS). However, due to the development of the In-Car Video Recording System Policy (see ER 10.8.A) and the need for the Body Worn Camera policy to be consistent with the new policy, additional revisions were necessary. Therefore, the most updated version of the Body Worn Camera Policy was still pending full dissemination in Q4 and resulted in a finding of partial compliance again at that time. The policy has now been fully disseminated to UCPD personnel and evidence of such is available to the Monitor via PowerDMS.


The Organizational Development Coordinator, Training Section, and Lieutenant Tim Barge collaborated to create a PowerDMS test on the contents of the policy. The questions and results may be viewed by the Monitor in PowerDMS. At the time of the initial implementation of the body camera usage (2014), the attached training, policy sign-off, and equipment sign-out rosters were completed. Finally, the Monitor has also been provided access to the UCPD Body Camera video recordings to test implementation of the current policy.” Data Reviewed Body Worn Camera Digital Recording System Policy, SOP 9.1.700 Prior Assessments of Compliance As a result of its first assessment during Q2 ending June 30, 2017, the Monitor found the UCPD in partial compliance. While the Monitor’s review of the UCPD’s updated Body Worn Camera (“BWC”) Digital Recording System policy found that it adequately addressed the requirements of the ER, it had not been disseminated as of the end of that reporting period. The Monitor again assessed compliance with this ER during Q4, and while the UCPD had made appropriate additional revisions to the policy based on corresponding edits to the In-Car Camera policy, they were made towards the end of the reporting period. Consequently, the UCPD was unable to fully disseminate the Body Worn Camera (“BWC”) Digital Recording System policy prior to the close of that reporting period as well. Current Assessment of Compliance

In Compliance

During the current quarter, the Monitor confirmed that the last version of the updated Body Worn Camera (“BWC”) Digital Recording System policy was disseminated and a suitable test was given as stated in the UCPD’s proffer of compliance (above in italics). While the Monitor has reviewed select body camera video recordings related to other areas of the monitorship and it appears that officers are conducting the pre-check as required, the Monitor has noted several instances of delayed activation of the officer’s body camera. The UCPD has conducted internal reviews of these instances and has taken corrective measures to prevent similar occurrences. The Monitor notes that its final review of this ER will also include a random sampling of body camera video and the connected supervisory reviews to ensure complete implementation of this policy. Next Review The Monitor will conduct its final assessment of the UCPD’s compliance in Q9 for the period ending March 31, 2019. While the Monitor has reviewed select body camera video recordings related to other areas of the monitorship; the final review of this ER will also include a random sampling of body camera video and the connected supervisory reviews to ensure complete implementation of this policy.



DATE: JANUARY 30, 2018 REC. REF. NO.: 11.5.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding Currently, officers must return to a station or substation to complete a report in ARMS. Exiger Recommendation (“ER”) The UCPD should consider implementing an ARMS Mobile Product on MDCs and/or tablets to enable officers to complete reports from the field. This could be accomplished by issuing a mobile device to each officer, or by deploying tablets to various locations across campus. MADC Definition of Compliance Compliance with this provision will be achieved when:

1) UCPD gives meaningful consideration to providing its officers with a mobile device or creating tablet stations at various locations across campus; and

2) If implemented, there provisions will allow officers to be able to complete reports in the field.

Proffer of Compliance “The University of Cincinnati, Department of Public Safety has considered acquiring and implementing a mobile product on MDC’s or tablets to allow for in-field reporting. The consideration of tablets, which was declined, is contained in memo 2.1.D. The ARMS system utilized for reporting does have a mobile version which could be loaded onto an MDC, however, the mobile version does not allow for full functionality of the system. If a mobile version were to be implemented, the officers would still need to respond to the office/station on all campuses to use a hardline computer to complete their report. Additionally, the University is a participant with all Hamilton County, Ohio police agencies in our hardware and software that supports dispatching and data collection of officer activities through the county Regional Crime Information Center (RCIC). RCIC will not allow us to load our ARMS software onto any device (MDC) that was linked into RCIC. Finally, the small geography of our jurisdiction allows our officers to return to the station/office (on all of our campuses) to use a hardline computer for data entry without removing the officer far from their assigned areas of patrol. For these reasons, we have determined that adopting an in-field reporting capacity is neither necessary nor efficient for UCPD.”


Data Reviewed None


As described in the UCPD’s proffer of compliance (above in italics), the UCPD has given due consideration to the ER and has appropriately explained the rationale surrounding the final decision. The Monitor appreciates the UCPD’s thorough evaluation of the issue and agrees with the UCPD’s conclusion that mobile reporting is not needed at this time. Next Review No further review of this ER is necessary.



DATE: MARCH 6, 2018 REC. REF. NO.: 11.10.B SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding Public Safety Technical Services lacks project management resources to manage system implementations. IT projects may be at risk not because of technical issues, but due to lack of proper project management. Exiger Recommendation (“ER”) Public Safety Technical Services should engage in a study to determine the appropriate Information Technology (“IT”) staffing levels. It appears that additional Technicians are likely required to support the IT needs of the Department. MADC Definition of Compliance Compliance with this provision will be achieved when:

1) the Public Safety Technical Services staff engages in a study on whether current IT staffing levels are appropriate to meet the needs of the Department; and,

2) UCPD changes IT staffing levels if necessary.

Proffer of Compliance “UC Public Safety has completed an IT staffing study which determined that two additional IT staff are needed to service all IT aspects of the department. A budget proposal for the two additional personnel has been created. Please see the attached staffing study overview, staffing study report, systems grid which lists the major Public Safety IT systems, and budget request for additional personnel.” Data Reviewed 1. 11.10.B Public Safety IT Staffing Overview 2. 11.10.B Public Safety IT Staffing Report 3. 11.10.B Systems Information Grid 2018 4. 11.10.B 2018-2019 Budget Proposal – IT Personnel



As described in the UCPD’s proffer of compliance (above in italics), the UC Public Safety (PS) IT Department, which supports the computer and technical needs of PS administration and the Police Division day-to-day police operations, has completed a staffing study. Since the prior study completed in 2009, an additional 69 new positions and at least 12 online systems were added. The new staffing study resulted in several key recommendations including hiring two additional Full Time Equivalent (FTE) positions, and structural changes to the IT department such as defining roles and responsibilities more clearly and implementing an on-call system for 24/7 support. The two FTEs have been requested in the upcoming budget, which the Monitor strongly supports. Next Review The Monitor will conduct a final assessment of the UCPD’s compliance with this ER in Q9 for the period ending March 31, 2019.

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec

12.1.A Integrate all data collection systems into one large database that tracks all of UCPD’s information.

12.2.A Ensure that access to stored CAD data is easily obtainable and meets UCPD’s mandated reporting functions to the state and federal governments

12.2.B Research whether the new CAD system from TriTech can be integrated into ARMS, and integrate if possible. - - - - - - - - - - -

12.2.C If integration is not possible, continue to use the CPD CAD. - - - - - - - - - - -

12.3.A Evaluate the ARMS module for Field Contacts, and ensure that all required data fields can be reported through the module. - - - - - - - - - - -

12.3.B If the data fields can not be included or the ARMS’ module for Field Contacts utilization is otherwise undesirable, maintain the MAD and ensure that all data is transferred into the ICS Dashboard. - - - - - - -

12.4.AWork with ICS and UCPD IT experts to identify standardized reporting from ARMS data in a variety of formats, such as bar graphs, pie charts and line graphs, that will assist UCPD in analyzing crime, operational, staffing and performance data on various indicators.

12.5.A Integrate the DPLF and PPF MADs into the ARMS system. If integration is not possible, continue to collect this data and ensure that the data can be exported into the ICS Dashboard. - - - - - - - - - -

12.6.A Work with ICS to further develop the functionality of the Dashboard.

12.6.B Capture data relative to race, gender, age and ethnicity, so as to better foster transparency and legitimacy. ¡

12.7.A Add the following fields to its MAD: whether the stop was a traffic or pedestrian stop, whether there was a frisk or search of the person or property, and whether force was used during the stop. ¡


Section 12 - Review of Data Collection Systems, Data Usage, Automation, and Records Management

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec


Section 12 - Review of Data Collection Systems, Data Usage, Automation, and Records Management12.7.B Monitor stop data regularly as part of an early warning system, surfacing potentially at-risk behavior

of policy violation or biased policing. ¡

12.8.A Continue to utilize the Guardian Tracking electronic database for documenting and tracking positive and negative aspects of employee performance.

12.8.BConduct a thorough review of the capabilities of the Guardian Tracking system and its potential interface with the ICS Dashboard, so as to allow for inclusion of Guardian Tracking data in ICS dashboards and more fulsome early warning system.

- - - - - - -

12.9.A Establish an electronic database to track and maintain data related to internal affairs complaints, and can readily communicate with other UCPD databases (ARMS).

12.10.A Establish an electronic database to track and maintain data related to uses of force, and investigations thereof, and can readily communicate with other UCPD databases (ARMS).

12.11.A Integrate the data and analysis available from the ICS tool into bi-weekly meetings and consider adding additional UCPD command staff to the meeting.

12.11.BInstitute a regular Compstat-like process which goes beyond just examination of crime data, analyzing other relevant information including Uses of Force, Complaints, and other performance-related issues

12.12.AUCPD should leverage the technology available in the ICS Dashboard to build a proactive risk management database, which will track and analyze risk related information, and data related to a series of performance indicators.

12.12.B Analysis should include the crime and performance data currently available in the Dashboard in order to obtain a more holistic picture of an officer’s performance.

12.12.CWork with ICS to establish appropriate performance thresholds triggers, including Department-Level Thresholds (e.g., 3 internal affairs complaints in 12 months); Peer Officer Averages (compares performance with similarly situated officers); and Performance Indicator Ratios (e.g., ratio of UOF

12.12.D Establish a protocol for the resolution of EWS notifications of potentially at risk officers. ¡

Q1:Jan-Mar

Q2:Apr-Jun

Q3:Jul-Sep

Q4:Oct-Dec

Q5:Jan-Mar

Q6:Apr-Jun

Q7:Jul-Sep

Q8:Oct-Dec

Q9:Jan-Mar

Q10:Apr-Jun

Q11:Jul-Sep

Q12:Oct-Dec


Section 12 - Review of Data Collection Systems, Data Usage, Automation, and Records Management12.13.A

Consider including the following data on its website: (1) yearly totals for Part 1 and significant Part 2 crimes; (2) an incident map; (3) the Daily Crime Log; (4) pedestrian and traffic stop totals broken down by demographic data; (5) use of force data broken down by type of force used and whether



DATE: JANUARY 30, 2018 REC. REF. NO.: 12.3.B SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD has not obtained access to ARMS’ module for Field Contacts, and instead uses a Microsoft Access database to track demographic data associated with pedestrian and traffic stops. This database, however, does not feed into ARMS. Exiger Recommendation (“ER”) If the data fields are not and cannot be included, or the ARMS’ module for Field Contacts utilization is otherwise undesirable, UCPD should maintain the Microsoft Access database and ensure that all data is transferred into the ICS Dashboard. MADC Definition of Compliance Compliance with this provision will be achieved when UCPD transfers data maintained in the Microsoft Access database into the ICS Dashboard, if the ARMS' module for Field Contacts is unattainable or undesirable. Proffer of Compliance “The Contact Card data continues to be maintained in the Microsoft Access database and loaded in the ICS Dashboard. The Access database is jointly maintained by the Clery Coordinator and Records Manager. Document Request #106 contains the Access database for 2017 field contact cards. The data then transfers through an automatic pull from the server, by Dr. Murat Ozer in ICS. A screenshot of the ICS dashboard containing recent contact cards is attached. Data on the ICS Dashboard matches what is entered into the Access database, and may be downloaded into an Excel file. Although the ICS Dashboard is still currently updated and access by UCPD personnel, the UCPD plans for the crime analyst to create all analytical products for the UCPD moving forward and will eventually phase out the use of the ICS Dashboard. The crime analyst has already produced numerous analytical products for review by supervisory staff and the crime reduction group to supplement the ICS Dashboard, but full analytical capability is dependent upon being able to access all necessary data, which will be covered by the updated data sharing agreement with the City of Cincinnati. At this time, the timeline for completion of this is unknown. The monitor will be advised of the UCPD’s progress and can be provided examples of the analyses conducted to date upon request.” Data Reviewed 1. Onsite review of Contact Cards 2. Excel Sheet containing data


3. Screenshot of the UCPD Contact Cards page on the ICS Dashboard Prior Assessment of Compliance The Monitor last assessed the UCPD’s compliance with this ER in Q1 ending March 31, 2017 and found that the UCPD had continued to transfer Contact Card data from the MAD to the ICS Dashboard. Current Assessment of Compliance

In Compliance

As described in the UCPD’s proffer of compliance (above in italics), and confirmed by the Monitor during its onsite review, the UCPD continues to maintain the Contact Card Data Microsoft Access database, the information of which is then loaded in the ICS Dashboard. Next Review No further review of this ER is necessary.



DATE: FEBRUARY 10, 2018 REC. REF. NO.: 12.6.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD works with ICS on crime analysis. ICS has developed a visual, analytic tool that pulls crime data from both the CAD and ARMS systems, and analyzes crime, individual officer activity, staffing levels, and overtime expenditures. The tool can pull data from several different types of database applications, including Microsoft Access, and display the data in a variety of different ways on a dashboard customized to exhibit relevant information at different levels of responsibility with UCPD and its supervisors. Exiger Recommendation (“ER”) UCPD should continue to work with ICS to further develop the functionality of the ICS tool and its Dashboard. MADC Definition of Compliance Compliance with this provision will be achieved when UCPD continues to work with ICS to further develop the functionality of the ICS tool and its Dashboard. UCPD Proffer of Compliance “The UC Crime Reduction Committee began in 2013, as a way for the UCPD to collaborate to reduce crime in the areas near the UC Uptown Campus with the Cincinnati Police Department. This committee continues to meet on a bi-weekly basis to examine crime trends, deployment strategies, and discuss any crime and/or disorder problems which need to be addressed by the University. Since late 2016, the committee has continued to examine crime trends through the ICS Visual Analytics Dashboard (“ICS tool”) during meetings. Meeting notes from three UC Crime Reduction meetings are attached as evidence of the continued use of the ICS tool during the meeting. Two screenshots of Dashboard information discussed during Crime Reduction Meetings are also attached. UCPD command staff regularly attend these meetings, as is shown in the meeting notes of attendees.

Although the ICS Dashboard is still currently updated and access by UCPD personnel, the UCPD plans for the crime analyst to create all analytical products for the UCPD moving forward and will eventually phase out the use of the ICS Dashboard. The crime analyst has already produced numerous analytical products for review by supervisory staff and the crime reduction group to supplement the ICS Dashboard, but full analytical capability is dependent upon being able to access all necessary data, which will be covered by the updated data sharing agreement with the City of Cincinnati. At this time, the timeline for completion of this is unknown. The monitor will be


advised of the UCPD’s progress and can be provided examples of the analyses conducted to date upon request.” Data Reviewed None Current Assessment of Compliance

In Compliance

As described in the UCPD’s proffer of compliance (above in italics), the purchase of a new system to replace ICS seems the best option at this time, which, along with the expertise of the newly hired crime analyst, should provide the UCPD with a significant increase in its data analysis capabilities. Next Review The Monitor will again assess the UCPD’s compliance with this ER during Q9 ending March 31, 2019.



DATE: FEBRUARY 10, 2018 REC. REF. NO.: 12.8.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD is currently using the Guardian Tracking software to document employee performance and to flag potential patterns in employee performance for early intervention. The interface of Guardian Tracking is simple and user-friendly, but UCPD is not currently using the categories and sub-categories correctly. Exiger Recommendation (“ER”) UCPD should continue to utilize the Guardian Tracking electronic database for documenting and tracking positive and negative aspects of employee performance. MADC Definition of Compliance Compliance with this provision will be achieved when UCPD continues to utilize the Guardian Tracking electronic database for documenting and tracking positive and negative aspects of employee performance. Proffer of Compliance “UCPD continues to use the Guardian Tracking Employee Documentation / Early Intervention & Recognition System software in order to document both positive and negative aspects of employee performance. The most recent paid invoice for this software is attached. The monitor has been provided viewing permission to this software in order for them to remotely access and review supervisory monthly evaluations, complaints, and commendation data as evidence of the UCPD’s use of the electronic software. The Early Intervention System policy (attached) related to Guardian Tracking’s risk assessment capabilities will be disseminated to UCPD personnel after the monitor reviews it and evidence of such will be provided to the monitor via Power DMS at that time. The Managing Performance policy (ER 7.4.A), which will include procedures for monthly evaluations, awards and commendations, will be completed and submitted for assessment in Quarter 6 (April-June 2018).” Data Reviewed Invoice for Guardian Tracking annual subscription Prior Assessment of Compliance The Monitor last assessed the UCPD’s compliance with this ER in Q1 ending March 31, 2017. The Monitor agreed with the UCPD’s decision to continue, and in fact, increase its use of Guardian


Tracking as its tool for documenting employee performance and identifying potential patterns for early intervention. Current Assessment of Compliance

In Compliance

As described in the UCPD’s proffer of compliance (above in italics), and confirmed by the Monitor during its review of the Guardian Tracking System data, along with the related Early Intervention System policy, the UCPD is now taking full advantage of the Guardian Tracking System for documenting and tracking positive and negative aspects of employee performance. Next Review The Monitor will conduct its final assessment of the UCPD’s compliance with this ER during Q9 ending March 31, 2019.



DATE: APRIL 10, 2018 REC. REF. NO.: 12.8.B SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD is currently using the Guardian Tracking software to document employee performance and to flag potential patterns in employee performance for early intervention. The interface of Guardian Tracking is simple and user-friendly, but UCPD is not currently using the categories and sub-categories correctly. Exiger Recommendation (“ER”) Conduct a full review of the capabilities of the Guardian Tracking system and its potential interface with the ICS tool with an eye toward including Guardian Tracking data in ICS dashboards and therefore building a more fulsome early warning system. MADC Definition of Compliance Compliance with this provision will be achieved when UCPD gives meaningful consideration to including Guardian Tracking data in the ICS Dashboards; and if feasible, UCPD integrates the two systems. UCPD Proffer of Compliance “The Guardian Tracking performance management software is used by the UCPD to document both positive and negative aspects of employee performance. The most recent paid invoice for this software is attached. The UCPD’s use of the Guardian Tracking software was previously hampered by software designs that produced an unwieldy number of categories from which supervisors could select and resulted in inconsistent use across users. In an attempt to remedy these issues and as part of a full review of the capabilities of the Guardian Tracking System, the UCPD designated an internal Performance Improvement Team (PIT) to work collaboratively with the software developer on improvements needed for the division’s advanced analytical demands. Due to the non-renewal of the ICS contract (see DR 0164), rather than explore the potential for interface with the ICS tool as originally recommended, the UCPD PIT instead sought to increase its capabilities within the Guardian Tracking software, including as an early warning system as recommended in ER7.2.A. The Organizational Development Coordinator was charged with chairing the PIT. Other members included: Former Chief Carter, Chief Herold, Acting Assistant Chief Dudley Smith, Captain Carter, Captain Thompson, LT Hoffman, SGT Maxwell, Kimberly Willis, and Lixuan Zheng (IT). The team met on the following dates: 9-13-17, 9-27-17, 10-11-17, 11-7-17, and 11-29-17, while the ODC took the lead on collaborating with the Guardian Tracking representatives in between these meetings. The PIT’s most cumbersome task was to significantly streamline the existing 92 categories, many of which were ambiguous and/or overlapping (see attached). Their work


resulted in paring these down into eight main categories with subcategories for each (see attached for revised list). Once the new categories were established, the historical data previously entered was converted into the new categories (see attached for recoding guide). The PIT team also worked with Guardian Tracking to increase the software’s capabilities as an early intervention system with supervisory alerts to potentially at-risk behavior by officers. The Early Intervention System policy (attached) specifically includes a protocol for the resolution of threshold notifications of potentially at-risk officers on pages 4-5. In PowerDMS, the monitor may access the list of categories and how they contribute to an early intervention flag (i.e., how they are weighted). A screenshot is also attached. The Early Intervention System policy will be disseminated to UCPD personnel after the monitor reviews it and evidence of such will be provided to the monitor via Power DMS at that time. The Managing Performance policy (ER 7.4.A), which will include procedures for monthly evaluations, awards and commendations, will be completed and submitted for assessment in Quarter 6 (April-June 2018) and subsequently disseminated after the monitor reviews it. The PIT team also collaborated with Guardian Tracking to improve the software's capabilities for supervisory evaluations of subordinates. Specifically, they were able to transform supervisory monthly evaluations from two different paper forms to an electronic process completed and stored within the Guardian Tracking System (see attached for monthly evaluation template). Finally, the Guardian Tracking System's staff visited the UCPD HQ to conduct supervisory training on the revised performance management categories and new capabilities of the software on December 14, 2017. This was preceded by an email to supervisors from the ODC to explain the category overhaul, the software improvement process, and provide a link to a training video that would supplement Guardian’s on-site supervisory training (all attached).” Data Reviewed 1. Invoice for Guardian Tracking annual subscription 2. Previous Guardian Tracking Categories 3. Revised Guardian Tracking Categories 4. Guardian Tracking Category Recoding Guide 5. Early Intervention System Policy 6. Notification Threshold Screenshot 7. Monthly Evaluation Template 8. Email to Supervisors 9. Training Video for Supervisors


In Compliance

As is clearly described in the UCPD’s proffer of compliance (above in italics), and was confirmed during the Monitor’s review of the newly streamlined categories in GTS, the UCPD has indeed overhauled the GTS with an eye toward a future more robust Early Warning System (EWS). While the ICS data will no longer be a factor in the EWS buildout, the Monitor understands that the newly


hired Crime Analyst is working on a dashboard to include monthly activities by officer. It is precisely that kind of information/data which can be used to ensure an accurate picture of officer performance is used when drafting evaluations. Next Review Given that ER 12.12.D covers the implementation of the EWS and ER 7.2.A covers the implementation of both the EWS and performance evaluation system, both of which will be assessed in Q6 and forward, no further review of this ER is needed.



DATE: MARCH 10, 2018 REC. REF. NO.: 12.11.A SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD does not utilize a regular CompStat management accountability process with UCPD personnel. UCPD Command Staff does, however, participate in bi-weekly crime reduction meetings with CPD Command Staff and UC Administrators to discuss crime trends and enforcement strategies for the UC campus and the immediate area surrounding the campus. Exiger Recommendation (“ER”) UCPD should better integrate the data and analysis available from the Institute of Crime Science (ICS) tool into the bi-weekly UCPD/CPD meetings and should consider adding additional UCPD command staff to the meeting. MADC Definition of Compliance Compliance with this provision will be achieved when the UCPD integrates the data and analysis available from the ICS tool into the bi-weekly UCPD/CPD meetings; and gives meaningful consideration to adding additional UCPD command staff to the bi-weekly UCPD/CPD meetings. Proffer of Compliance “The UC Crime Reduction Committee began in 2013, as a way for the UCPD to collaborate to reduce crime in the areas near the UC Uptown Campus with the Cincinnati Police Department. This committee continues to meet on a bi-weekly basis to examine crime trends, deployment strategies, and discuss any crime and/or disorder problems which need to be addressed by the University. Since late 2016, the committee has continued to examine crime trends through the ICS Visual Analytics Dashboard (“ICS tool”) during meetings. Meeting notes from three UC Crime Reduction meetings are attached as evidence of the continued use of the ICS tool during the meeting. Two screenshots of Dashboard information discussed during Crime Reduction Meetings are also attached. UCPD command staff regularly attend these meetings, as is shown in the meeting notes of attendees.

Although the ICS Dashboard is still currently updated and access by UCPD personnel, the UCPD plans for the crime analyst to create all analytical products for the UCPD moving forward and will eventually phase out the use of the ICS Dashboard. The crime analyst has already produced numerous analytical products for review by supervisory staff and the crime reduction group to supplement the ICS Dashboard, but full analytical capability is dependent upon being able to access all necessary data, which will be covered by the updated data sharing agreement with the City of Cincinnati. At this time, the timeline for completion of this is unknown. The monitor will be advised of the UCPD’s progress and can be provided examples of the analyses conducted to date upon request.”


Data Reviewed 1. UC Crime Reduction Committee meeting notes from 10/25/17, 12/20/17 and 1/10/18. 2. UC Crime Reduction Committee Dashboard screenshot examples 1 and 2 Prior Assessment of Compliance The Monitor last assessed the UCPD’s compliance with this ER in Q1 ending March 31, 2017 and found the UCPD in compliance with this ER. The Monitor confirmed that the UCPD was working with ICS on crime analysis and was regularly attending the weekly Crime Reduction Committee meetings in an effort to reduce the incidence of crime. Current Assessment of Compliance

In Compliance

As described in the UCPD’s proffer of compliance (above in italics), and confirmed by the Monitor during its review, the UCPD continues to use the ICS Dashboard as a tool to analyze crime information and collaborates with neighboring partners to proactively reduce the incidence of crime on and around campus. Next Review The Monitor will conduct its final assessment of the UCPD’s compliance with this ER during Q9 ending March 31, 2019.



DATE: APRIL 10, 2018 REC. REF. NO.: 12.12.D SUBJECT: ASSESSMENT OF COMPLIANCE Exiger Finding UCPD does not have a proactive risk management program, and does not track important performance data, including data related to internal affairs complaints and use of force incidents. Furthermore, UCPD does not effectively utilize the Guardian Tracking system to full capacity, by effectively identifying and monitoring employee performance. Exiger Recommendation (“ER”) UCPD should establish a protocol for the resolution of Early Warning Systems notifications of potentially at-risk officers. MADC Definition of Compliance Compliance with this provision will be achieved when: 1) UCPD implements policies and procedures for the resolution of Early Warning Systems (EWS) notifications of potentially at-risk officers; 2) These policies and procedures meet best practices in the industry; 3) These policies and procedures are being followed in practice. UCPD Proffer of Compliance “The Guardian Tracking performance management software is used by the UCPD to document both positive and negative aspects of employee performance. The most recent paid invoice for this software is attached. The UCPD’s use of the Guardian Tracking software was previously hampered by software designs that produced an unwieldy number of categories from which supervisors could select and resulted in inconsistent use across users. In an attempt to remedy these issues and as part of a full review of the capabilities of the Guardian Tracking System, the UCPD designated an internal Performance Improvement Team (PIT) to work collaboratively with the software developer on improvements needed for the division’s advanced analytical demands. Due to the non-renewal of the ICS contract (see DR 0164), rather than explore the potential for interface with the ICS tool as originally recommended, the UCPD PIT instead sought to increase its capabilities within the Guardian Tracking software, including as an early warning system as recommended in ER7.2.A. The Organizational Development Coordinator was charged with chairing the PIT. Other members included: Former Chief Carter, Chief Herold, Acting Assistant Chief Dudley Smith, Captain Carter, Captain Thompson, LT Hoffman, SGT Maxwell, Kimberly Willis, and Lixuan Zheng (IT). The team met on the following dates: 9-13-17, 9-27-17, 10-11-17, 11-7-17, and 11-29-17, while the ODC took the lead on collaborating with the Guardian Tracking representatives in between these meetings. The PIT’s most cumbersome task was to significantly streamline the existing 92


categories, many of which were ambiguous and/or overlapping (see attached). Their work resulted in paring these down into eight main categories with subcategories for each (see attached for revised list). Once the new categories were established, the historical data previously entered was converted into the new categories (see attached for recoding guide). The PIT team also worked with Guardian Tracking to increase the software’s capabilities as an early intervention system with supervisory alerts to potentially at-risk behavior by officers. The Early Intervention System policy (attached) specifically includes a protocol for the resolution of threshold notifications of potentially at-risk officers on pages 4-5. In PowerDMS, the monitor may access the list of categories and how they contribute to an early intervention flag (i.e., how they are weighted). A screenshot is also attached. The Early Intervention System policy will be disseminated to UCPD personnel after the monitor reviews it and evidence of such will be provided to the monitor via Power DMS at that time. The Managing Performance policy (ER 7.4.A), which will include procedures for monthly evaluations, awards and commendations, will be completed and submitted for assessment in Quarter 6 (April-June 2018) and subsequently disseminated after the monitor reviews it. The PIT team also collaborated with Guardian Tracking to improve the software's capabilities for supervisory evaluations of subordinates. Specifically, they were able to transform supervisory monthly evaluations from two different paper forms to an electronic process completed and stored within the Guardian Tracking System (see attached for monthly evaluation template). Finally, the Guardian Tracking System's staff visited the UCPD HQ to conduct supervisory training on the revised performance management categories and new capabilities of the software on December 14, 2017. This was preceded by an email to supervisors from the ODC to explain the category overhaul, the software improvement process, and provide a link to a training video that would supplement Guardian’s on-site supervisory training (all attached).” Data Reviewed 1. Invoice for Guardian Tracking annual subscription 2. Previous Guardian Tracking Categories 3. Revised Guardian Tracking Categories 4. Guardian Tracking Category Recoding Guide 5. Early Intervention System Policy 6. Notification Threshold Screenshot 7. Monthly Evaluation Template 8. Email to Supervisors 9. Training Video for Supervisors


Partial Compliance

As is clearly described in the UCPD’s proffer of compliance (above in italics), and was confirmed by the Monitor by way of its collaborative review of and revisions to the Early Intervention System policy and its review of the ample documentation submitted - the UCPD is taking affirmative steps


towards the buildout of a comprehensive Early Warning System. While the ICS data will no longer be a factor in the EWS buildout, the Monitor understands that the newly hired Crime Analyst is working on a dashboard to include monthly activities by officer. That type of information/data can and should be used in place of the ICS data in order to get an accurate picture of officer performance. The Monitor understands that the UCPD has opted to draft a separate policy to cover the Performance Evaluation aspects of the system and ER requirements. While UCPD supervisors are currently completing and documenting the evaluations within the GTS, the policy and protocol has yet to be finalized. The Monitor looks forward to reviewing that policy in the coming weeks once it is submitted for assessment. Next Review The Monitor will again assess compliance with this ER in Q6 ending June 30, 2018 to include a review of EWS notifications and the actions taken, along with documentation related to performance evaluations.

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